Course Details

FDIC Guidance On Overdraft Protection

Webinar: ID# 1026416
Recorded CD
About This Course:
Financial institutions have been increasingly relying on overdraft income in recent years, which includes fees collected from automated overdraft programs.

With the increase in implementation of these programs, regulatory agencies have found a higher risk of harm to consumers, especially vulnerable consumers. The FDIC has issued guidance to ensure institutional compliance with the various regulations of overdraft programs.

With heightened oversight of these programs, officers and directors must understand what is required to maintain a compliant overdraft program and what pitfalls to avoid.

This webinar will help those responsible for overdraft programs understand best-practice measures for a program and how to implement effectively.

In addition to reviewing the FDIC requirements and recommendations, you will review the broader regulatory landscape that impacts overdraft programs and understand how your respective institution can implement a program with fidelity.


Requirements of FDIC Overdraft Payment Program Guidance
  • Automated vs. Ad Hoc Programs
  • Excessive Use and Meaningful Follow-up
  • Fees
Additional Regulatory Requirements
  • Regulation E – Electronic Funds Transfer
  • Regulation DD – Truth in Savings
  • Regulation O – Insider Lending
  • Unfair Deceptive Abusive Acts and Practices
  • Oversight of Third Party Programs
Implementation Considerations
  • Disclosure Requirements
  • Board Involvement
  • Examinations
About The Presenter

Jesse R. Johnston
  • Associate Attorney at Dickinson Mackaman Tyler & Hagen, P.C. of Des Moines, Iowa
  • Practice emphasizes assisting large and small financial institutions understand and effectively implement regulations, merger and acquisitions, third-party vendor management, and advising directors on board governance
  • Presenter, "Ongoing Oversight of 3rd Party Vendors: How to Manage the Love-Hate Relationship," 2016 Iowa Banking Law Seminar, West Des Moines, September 7, 2016
  • Wrote "Common Sense Changes to Reduce Call Report Burdens", Iowa Banking Law Blog, August 22, 2016
  • Wrote "Some Regulatory Relief: Rule Amending GLBA Annual Notice Requirements Proposed", Iowa Banking Law Blog, July 14, 2016
  • Presenter, "You Are Your Brother's Keeper: Managing Third Party Vendor Agreements," 2016 Cybersecurity Seminar, Des Moines, June 24, 2016
  • Wrote "Credit Where Credit Is Due: Iowa Supreme Court Rules Overdraft Protection Is Not Credit", Iowa Banking Law Blog, January 27, 2016
  • Wrote "Marketing Service Agreement or Something More? CFPB Targets Mortgage-Related Companies", Iowa Banking Law Blog, November 13, 2015
  • Presenter, "Case Law Update", 2015 Employment Law Client Seminar, Dickinson, Mackaman, Tyler & Hagen, P.C., October 21, 2015, West Des Moines, Iowa
  • Presenter, "Recent Enforcement Actions", 2015 Iowa Banking Law Seminar, Dickinson, Mackaman, Tyler & Hagen, P.C., September 10, 2015, West Des Moines, Iowa
  • B.A. and J.D. degree, Drake University
FDIC Guidance On Overdraft Protection
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Course Details
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