Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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Overdraft and non-sufficient funds (NSF) fees are currently one of the hottest topics in both regulatory compliance and risk management. While overdraft and NSF fees have been around for decades, the regulators have recently been identifying certain practices that they consider unfair and illegal in regards to certain overdraft and NSF fee practices.
In other words, the regulators are now saying that a few overdraft and NSF practices violate UDAAP. This means that certain overdraft and NSF fees that have been assessed and presumed acceptable for decades, are now suddenly being considered to be illegal practices that carry major consequences. While all overdraft and NSF fees are not prohibited and some fees may be legitimate, it is important that financial institutions ensure they fully understand the concerns identified by the regulators.
Our Overdraft and NSF Fees training program takes a deep dive into recent guidance relating to overdraft and non-sufficient funds (NSF) fees. Specifically, we have divided our program into two different parts. The first part of the program discusses two practices the CFPB addressed during late October 2022. These practices include both fees for retuned items as well as overdraft fees charged when an item was authorized positive, but was paid when the balance in the account was negative (i.e. authorize positive, settle negative). While the authorize positive, settle negative practice has had quite a bit of discussion over the last half of a decade, this is the first time we have heard concerns about return item fees. In the second part of our program, we discuss another emerging risk related to charging a non-sufficient funds fee for multiple represented items. While the focus of our program is guidance that was released by the FDIC and is (at the moment) only really applicable to FDIC-regulated institutions, we believe the FDIC guidance should be considered and followed by all financial institutions as other agencies have been discussing this topic over the last year.
Regardless of your regulator, it is important that all financial institutions review and evaluate their overdraft and NSF fee practices as this growing hot topic has already resulted in significant fines and penalties for several financial institutions.
This program would be good for risk managers, compliance officers & compliance team members, auditors, deposit/operations managers, and even senior management.
There are three different ways to access our Overdraft & NSF Fees program:
Individual Class. The easiest way to access our new Overdraft & NSF Fees program is to purchase our stand-alone class.
Fall 2022 Quarterly Compliance Update. The Overdraft & NSF Fees program is included as Part II of our Fall 2022 Quarterly Compliance Update. Our Fall 2022 Quarterly Compliance Update covers regulatory activity that took place during the third quarter of 2022. You can learn more about our Fall 2022 Quarterly Compliance Update at www.compliancecohort.com/fall-2022-quarterly-compliance-update.
Premium Membership. Each of our premium members automatically have access to this program through our Fall 2022 Quarterly Compliance Update - which is included as part of each premium membership.
Regular $349
Demo Available: If you would like to demo this class before you purchase it to make sure it's what you are looking for, just let us know and we can set you up with preview access.
The total teaching time of this program is 1 hour 34 minutes and is divided in two videos.
Video 1 - CFPB’s October 2022 Guidance on Overdrafts (52 min)
Introduction and History
Overview of the CFPB’s October 2022 Guidance
Surprise Depositor Fees (Return Check Fees)
Surprise Overdraft Fees (Authorize Positive, Settle Negative)
CFPB Orders Regions Bank to Pay $191 Million for Illegal Surprise Overdraft Fees
Video 2 - Non-Sufficient Funds (NSF) Fees (42 min)
Massachusetts Issues Supervisory Alert Letter
FDIC Consumer Compliance Supervisory Highlights March 2022
CFPB: Consumers on course to save $1 billion in NSF fees annually
Industry Letter: Avoiding Improper Practices Related to Overdraft and Non-Sufficient Funds Fees
FDIC Guidance on Multiple Re-Presentment NSF Fees
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This Compliance Class can be completed without leaving your office and provides you with everything you need to know about what compliance related activity took place during the prior quarter.
The class includes the following:
A comprehensive manual
A “virtual classroom” instructional video
60-day access to the class
Certificate of completion (1 per registration - available upon request)
All of our Compliance Classes are presented in our virtual classroom approach. This approach is designed to bring the presenter to you (at a fraction of the cost of having a live person) and includes a video of the presenter in front of a slide presentation that replicates a typical seminar environment. In addition, our presenters take a three-part approach to compliance instruction: to educate, to empower, and to entertain. This is achieved by focusing on relevant topics, speaking in simple to understand, layman's terms, and by keeping it light and humorous whenever possible. We have found that this "3-E" approach allow students to learn as quickly and effectively as possible. And, it adds a little bit of fun to an otherwise dreadful topic.
Certificates of completion are available upon request. One certificate is available per registration.
When you purchase this compliance class, you get instant access to the online version of this class for 60 days. You will also receive an electronic version of the accompanying manual to keep.
We believe in our training products so much that we are offering a 100% money back guarantee within the first 10 business days after purchase. If you do not feel that you received the value promised for this training session, contact us within the first 10 business days after purchase and we will either make things right or provide 100% of the purchase price back to you.
