Overdraft Privilege Provides a Solution for Charging Multiple NSF Fees

When a merchant transaction is presented for payment from a consumer account and is refused due to the customer’s insufficient funds to cover the transaction, financial institutions typically charge an NSF fee. When a merchant tries to present the same transaction again in order to recover the denied funds, he or she may be charged a re-presentment NSF fee. If a depository institution receives this type of repeated merchant payment transaction more than once, the depository institution may levy multiple NSF fees. If an Automated Clearing House (ACH) or other item is presented for payment and is denied owing to insufficient funds, certain financial institutions will levy an NSF fee for both the original presentment and each subsequent representation.

In recent class action lawsuits against financial institutions, the removal of key clauses pertaining to the assessment of representation fees was considered to be a violation of contract. Some lawsuits have been settled, with customers receiving refunds and legal fees.  Additionally, state, and federal financial regulators are reviewing DDA agreements searching for potential legal, regulatory and UDAP risks. With these potential risks it is important to review your deposit disclosures and contract language to ensure the way NSF fees are charged is being communicated clearly and consistent to what a consumer could reasonably expect.

This is a great time to make sure that you review your accounts and all of your customers/members that are eligible for Overdraft Privilege should be added to the ODP program unless they have opted out of the program.  By doing this it will minimize your risk for NSF fees being represented, because if your customers/members have an Overdraft limit their items will be considered for payment instead of returned.  Paying the item instead of returning it will ensure that the financial institution minimizes its risk for NSF re-presentments because the item is not returned.  Also, overdraft privilege provides a better service to your customers/members because they will not be faced with potential late fees, retailer fees and damage to their credit from returned items.

Accept Electronic Consent to Opt In for Regulation E

ODP Manager helps you distribute your Consent Form for Overdraft Services to your customers that have not already opted in for Reg E by including the opt in form with Welcome letters, Reinstatement letters, and the Reg E Opt-in Followup letter. This makes it easy for customers that would like to opt in by mail, but there are three other methods for a customer to opt in: in person, by phone, or electronically. The Reg E opt in form will direct your customers to the appropriate mailing address, phone number to call, or to visit a branch, but are you prepared to accept an electronic response?

ODP Manager includes a feature which can assist you in obtaining your customer’s electronic consent to opt in to ODP coverage for ATM and everyday debit card transactions. Strunk can create a Reg E opt in form and Reg E opt out form that mirrors the content in your ODP Manager letters. You would then add links to these forms to your website.

When your customer visits your website and completes either the Consent Form for Overdraft Services or the Consent to Opt-Out, they will receive an email confirmation of their Reg E election. Also, this response will be tracked in ODP Manager and can be emailed to a designated email address at your financial institution.

Your ODP Manager users will review the new responses in ODP Manager, export a list of accounts that need an update to their Reg E election, and perform the appropriate maintenance in your core software – updating the account record to either opt in or opt out the customer’s requested account. By default, the hosted ODP Manager software displays new responses that have not been reviewed and exported. Prior submissions are also retained to allow your users to review previous responses.

If you would like to set up ODP Manager to accept electronic consent to opt in for Overdraft Privilege coverage for ATM and everyday debit card transactions, please contact Strunk Support at support@strunkaccess.com with any questions or to find out more.

Bankers: How to Make Consumer Loans Profitably

For the past 40 years banks have refrained from making small dollar consumer loans due to the unprofitable nature of doing so. Industry experts say it costs anywhere from $85-$100 to book an installment loan and the interest received wouldn’t cover the expense. Even though in the 1990’s banks starting charging an application fee to cover this expense most bankers cringe when asked to make an $800 consumer loan…until now.

Quilo allows financial institutions to underwrite, fund, collect, and report the loans for around $.85, not $85. The smart phone lending tool gives instant access to installment loans from your bank 24/7, in the back pocket or purse of your customer.

The digital lending solution lets consumers apply via your website in about two minutes. Then they use the Quilo app to pay down or pay off other bank’s credit cards, replenish their checking account for recent debit card purchases of over $250, or get a virtual prepaid MasterCard to be used for online or POS purchases.

It can be used anywhere Apple Pay, Google Pay or Samsung Pay is accepted, added to your digital wallet, or added to your online account at any merchant. The reloadable card is easy to use and the loan program is easy to manage.

Bankers are familiar with digital banking on the deposit side but not lending. To see how Quilo can be a huge competitive advantage for your bank contact Strunk at info@strunkaccess.com or 800-728-3116 for a 45 minute web demo.

Quilo is a great opportunity for credit unions

Strunk recently attended the Cooperative Credit Union Association’s CU Marketplace in Worcester, Massachusetts to introduce Quilo. Digital technology should be a top priority and Quilo is the #1 solution on the market – an all-digital loan and payment platform empowering credit unions to offer POS financing directly to account holders.

Strunk CEO Dan Roderick was proud to have the opportunity to present Quilo at the event’s Executive Luncheon and Strunk representatives had many great conversations with credit unions that were very excited about the program.

Quilos can be used for new purchases online or in store, to pay down credit card balances, or move funds to a checking account. Account holders will experience stress-free, instant access to funds via the digital experience online and on mobile devices, while credit unions will enjoy net income up to 5% ROA.

Quilo has also been selected by CU 2.0 as one of their picks for a fintech that will make the best partner. To read the full article click here.

If your credit union has not had the chance to look at Quilo yet, now is the time! Contact Strunk at info@strunkaccess.com to schedule a demo today!

The Importance of Employee Training for your Overdraft Program

Does your front-line staff have a biased opinion regarding overdraft privilege and present it in a negative tone?  Is your front-line staff having a hard time explaining overdraft privilege to your customers/members and not really sure what to say to them? If you haven’t had a chance to listen to your employees’ present overdraft privilege to your customers/members, especially Reg. E, Strunk recommends doing it now.  Your staff should explain overdraft privilege and its options to your customers/members in a clear, consistent, compliant, and impartial way.

Sometimes front-line employees do not understand the true benefits overdraft privilege can provide to the customer/member.  Some employees often have a bad perception of overdraft privilege because they associate it with disgruntled or confused account holders. This misunderstanding is one of the main reasons why overdraft privilege training and education are so important!  It is important to provide your employees with a script on how to present overdraft privilege and the benefits of opting into Reg. E. Employees that have practiced and memorized a customer/member-focused overdraft privilege and Reg. E script, ensure that the approach is compliant, succinct, and easy to grasp.

Using the technique of allowing the customer to choose how the financial institution should manage a transaction that would overdraw the customers/members account before the due date ensures their happiness and loyalty.  Strunk’s Overdraft Privilege training will provide a clear understanding of the overdraft program and provide consistent talking points to your employees.  After overdraft privilege training your employees will be equipped with correct and thorough knowledge regarding your program.  Strunk will ensure your employees are equipped with a non-biased, clear and compliant script that provides account holders accurate information so they can make the best decision possible for their situation.  Overdraft privilege training will increase your employees’ confidence as a result of this approach, which will boost their performance, productivity, and level of service to your customers/members.


Following Up with Frequent Overdraft Privilege Users

Financial institutions are expected to monitor excessive consumer Overdraft Privilege usage to inform customers of additional available options for overdraft protection. These options could be an Overdraft Protection Credit Line or an Overdraft Protection Transfer from another account with the financial institution.

FDIC regulated institutions are expected to give customers who overdraw their accounts on more than six occasions where a fee is charged in a rolling twelve-month period a reasonable opportunity to choose a less costly alternative and decide whether to continue with fee-based overdraft coverage. Strunk also recommends that institutions not regulated by the FDIC also communicate available alternatives to ODP on an annual basis to accounts with insufficient funds items.

ODP Manager can assist with sending letters advising your customers of the alternatives to Overdraft Privilege. If the ODP Manager import file includes data from the core system that indicates when an account has qualified for the letter by exceeding the threshold, the hosted software can automatically show when a letter is due to be sent. If the data is unable to be added to the extract file but qualifying accounts can be identified from an existing core report or other method, a letter can be generated, as needed, as an Ad Hoc letter.

Once the letter is generated, the letter is tracked and retained within the ODP Manager application.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more about using ODP Manager’s Excessive Use Notification letter.

Bankers: How to make your Small Business Clients Thrive

When was the last time your bank had a product or service that would substantially increase the sales of your small business customers? Are your small business customers considering leaving your bank for Fintech’s who offering something you can’t provide?

Fintech experts claim that virtually all small businesses will have some sort of buy now pay over time product by the end of 2023. The Fintech programs allow consumers to buy something and pay for it over time and the purchase is generally subsidized by the small business. What if your bank had a product that provides a similar service but you make the loan rather than have your client take a hit on the sales price?

For dentists, HVAC companies, veterinarians, furniture stores, tire stores, roofers or any small business with larger ticketed items, we have the answer. Industry data shows small businesses will increase sales by 30% or more if consumers can pay for the purchase over time. How can your bank participate in this fast growing business?

Quilo provides instant access to loans from your bank via a smart phone using your underwriting criteria. Consumers make purchases from your commercial customers and pay for them over time with a loan from you…and your small businesses are thrilled.

To see how Quilo can be a huge competitive advantage for your bank contact Strunk at 800.728.3116 or info@strunkaccess.com.

ODP Manager Account History

One major benefit of the hosted ODP Manager software is access to the software’s advanced history tracking. Key account events are tracked in the system and are searchable.

When the daily extract file from the core system is imported into ODP Manager, significant account status changes are tracked. Is the account newly overdrawn or now in good standing? Has an overdraft limit been added to or removed from the account? Has the consumer opted their account in to or out of ATM and everyday debit card transaction coverage according to Regulation E? Has the account been closed? These items are all tracked and retained in each individual account’s history.

When a user generates a collection, custom, or ad hoc letter, not only is the letter type, description, and date recorded, but also a PDF of the letter is saved and linked to the account history and the event history. All letters are stored within the application and can be regenerated at any time.

If a user needs to make further contributions to the account record, a comment or reminder can be created. Notes can be saved to the account as a comment. Reminders can be created for follow-up items with a specific due date. Both comments and reminders are accessible to all users and can include attachments.

Searching for events can be done for an individual account or across a range of dates. Individual account information is easily exported to PDF. Events occurring during a specified timeframe can be filtered and exported to Excel.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more about ODP Manager’s advanced event history tracking.

Quilo: Quick Installment Loan

When was the last time your lending team was excited when a customer came to the bank to borrow $750? My guess is nearly 40 years ago when credit cards took over unsecured installment lending business from community banks.

Each core processor has fees associated with booking a new installment loan and the average fee is at least $85 or more. So, if you make a $750 loan for one year at 7% interest your bank would make about $26 in interest income since the loan is amortizing each month. If a bank charged a $50 application fee then the customer would pay $76 and you would only lose $9 on that transaction…assuming there was no credit loss.

Quilo provides community banks a smartphone lending solution that provides instant access to installment loans from your bank. Consumers have 24/7 access to installment loans and no more taking an application online or in person and making a decision tomorrow or the next day. Quilo’s can be obtained in two minutes with the bank controlling the credit risk and return.

Digital banking has been around for some time but not on the lending side of the house. Younger consumers like to do almost everything on their cell phone. Why not allow them to get loans via their cell phone rather than just make deposits or transfer money.

We are thrilled to announce that Quilo was recognized as the Choice Award winner at the recent ICBA Convention in San Antonio.

Contact Strunk at info@strunkaccess.com or 800.728.3116 for a 45 minute web demo to see if Quilo is a fit for your bank.

The Importance of an Inherent Risk Survey

One of the most crucial and challenging parts of vendor management is managing the risk associated with each of your vendors.  There are numerous risks that may arise from a financial institution’s use of vendors.  Understanding the vendors inherent risk will help your financial institution to categorize and differentiate the risk for each of your vendors.

Inherent Risk represents internal and external risk to which the financial institution is exposed to because of the business activities in which it engages and the external environment in which the activities take place.  Inherent Risk results from the processes, activities, or transactions in which the financial institution is involved, including risk that exists as the financial institution enters new businesses or activities with the vendor.  There are several factors that impact the determination of the inherent risk of the vendor.

Strunk’s Vendor Manager software has compiled these factors into a Vendor Risk Assessment (Inherent Risk Survey), which enables financial institutions to present an accurate portrayal of the overall inherent risk with any vendor.  Having an accurate portrayal of the inherent risk that each of your vendor has, will allow the financial institution to lay a solid foundation for what oversight that will be assigned to the vendor based on the inherent risk rating.  Strunk’s inherent risk rating will classify the financial institutions vendors into four categories based on their inherent risk rating, which is calculated based on the risk exposure the product or service provided may expose to the financial institution.  The inherent risk rating of a vendor will drive the frequency of the ongoing due diligence monitoring of the vendor.  Based on the inherent risk rating the financial institution should determine how effective the vendor has implemented controls to help manage their risk which will mitigate potential risk exposure.  Understanding each of your vendors’ inherent risk is the first step for setting up the proper foundation for your vendor manger program.