Overdraft Programs: Avoiding an Exam Disaster

Tuesday, June 11th, 2024 10:00 am - 12:00 pm Central Time

A Program

Click Here to register for program $299.00

Click Here to register for program and receive recording $449.00

Overdraft programs continue to be a hot button for examiners, especially the CFPB. Despite the guidance and communications issued by the agencies, there is still confusion over what requirements actually apply to the programs you offer. In this webinar, we’ll review OD regulations and provide OD best practices.

This session provides a comprehensive review of OD regulatory guidance, including a discussion of how to address representment fees and overdraft fees resulting from APSN transactions in your policies and procedures. We will discuss how to develop effective policy and procedures, and best practices for handling the representment process and related fees. We'll discuss best practices for disclosures, fees, accountholder education, compliant marketing of OD programs, and ongoing monitoring of accountholder activity. We will also review OD issues identified through consumer complaints, examinations, and enforcement actions and provide recommendations for you to avoid similar mistakes.

What You'll Learn
  • Guidance for ad hoc vs. automated OD programs
  • Opt-in/Opt-out under Regulation E
  • Inherent risks of OD programs
  • Overdraft restrictions for employees and insider
  • Understanding the impact of UDAAP
  • Reporting OD details effectively to the board and management


Dawn Kincaid began her banking career while attending The Ohio State University. She has 19 years of experience in client service, operations, information technology, administrative and board relations, marketing, and compliance. Most recently Dawn served as the Senior Vice President of Operations for a central-Ohio-based community bank, where she created and refined policies and procedures, conducted self-audits and risk assessments, and organized the implementation of new products and services. Dawn has served in the roles of Compliance, BSA/AML, CRA, Privacy, and Security Officer. She has led training initiatives, prepared due diligence information, completed a variety of regulatory applications, coordinated internal and external audits, and exams, and presented for numerous state associations.