Help Your Customers Opt In for Regulation E Online

ODP Manager includes letter templates that allow your customers the opportunity to opt in for Regulation E so they can authorize Overdraft Privilege service for ATM withdrawals and everyday debit card purchases. Did you know that ODP Manager can also help you offer your customers the option to opt in on your website?

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 submits the Consent Form for Overdraft Services or the Consent to Opt-Out, the opt in or opt out request is tracked in ODP Manager. The customer also is emailed a confirmation of their Reg E submission. Periodically, you review the new customer responses in ODP Manager and generate a list of the accounts that need the Reg E election updated. You perform the appropriate maintenance in your core software – updating the account record to either opt in or opt out the customer’s requested account. The ODP Manager software always shows you the most recent responses that you have not yet reviewed. The list of submissions is retained so you can look up past responses.

Let ODP Manager expand your options to allow your customers to choose Overdraft Privilege coverage for ATM and everyday debit card transactions. Please contact Strunk Support at with any questions or to find out more about using this feature.

Managing your Vendor’s Service Level Agreements

Vendor Manager automates vendor due diligence, provides a practical framework for deciding which vendors to assess in depth, assesses the risks they present, and monitors their performance.

Defining and managing Service Level Agreements (SLAs) with your vendors is a very important aspect of your Vendor Manger program.  An SLA defines the level of service expected by you from a vendor, laying out the metrics by which that service is measured, and the remedies or penalties, if any, should the agreed-on service levels not be achieved.  Monitoring SLA takes place after the contractual agreement to meet the client expectations is executed. Having a central location to clearly identify, define and review your SLA is critical to your Vendor Manager program.

Being able to create reports to understand where potential problem areas with your vendor’s service that they are providing is key to a quality vendor manger program.  Strunk’s Vendor Manager software has the capabilities to help you manage your vendor’s SLAs and it provides a central repository to track your vendor’s performance to make sure they are meeting your business needs.

Use Strunk’s Vendor Manager to automate a cumbersome process into a well-organized, self-documenting work flow. In addition to tracking the performance against key SLAs, use Vendor Manager to maintain your list of key vendors and associated contracts, to assess the inherent risk presented by each vendor and to complete the annual review of each relationship.

Ensuring Employee Compliance With Policies and Procedures

Does your financial institution do annual employee reviews of compliance with your policies and procedures? If not you should. Training employees on specific areas of the bank is crucial to running a successful company and testing for product knowledge is critical to customer service.

All financial institutions have policies that are board approved on an annual basis and a set of procedures that are senior management approved. The question is do your employees know what the policies and procedure say and do they follow them?

In the middle of the 1980’s, the bank I worked at had a product knowledge contest with the winner receiving a trip to Las Vegas. There were three person teams and the questions came from all areas of the bank. So it was important to have a lending person, a retail person and an operations person on each team to have the correct answers. Needless to say, our team won.

Today, we don’t have product or policy knowledge contests but that doesn’t mean you can’t test your employees for knowledge of these. Strunk’s Skills Manager solution allows financial institutions to train your employees on products, procedures or policies. Then through the solution you can test their knowledge based on the training. Test results for each employee funnel up to one person responsible for the training. Many institutions use this for their security or ethics policy requiring their employees to take a test on an annual basis. Could Skills Manager help your financial institution?

Charge Off Items and Recoveries

ODP Manager includes the letters that you need to notify customers that their account has been closed and charged off due to unpaid and outstanding overdrafts or due to a default on a Fresh Start Loan for outstanding overdrafts. Did you know that with Strunk’s most recent software releases, ODP Manager now includes tools that may help you manage your charge off and recovery process after the account has been closed?

At the account level, you can create a charge off item to track the charged off principal and fees. Users are able to add relevant notes and any updates will be logged. As recoveries are made, the recovery can be entered in ODP Manager and will reduce the overall balance tracked.

By default, users will view the Charge Off Items for the last year. If needed, users can select a different timeframe by specifying a start date and an end date. For reporting purposes, the summary of the Charge Off Items can be exported as a PDF.

Please contact Strunk Support at with any questions or to find out more about using this feature.

Is risk always bad?

In our industry we are accustomed to thinking of risk as something we need to constantly assess and evaluate. At best, this exercise can be laborious and time-consuming. The number of risk factors to consider can run into the hundreds, often with different parts of the organization best qualified to assess each risk. The typical solution, emailing spreadsheets around the organization, is inherently cumbersome and error-prone.

Let’s take a step back and break down what a risk is. The definition of risk is a situation involving exposure to danger. But danger does not always look like we might expect. There is an important distinction to be made as some risks can actually pose a benefit to any company while others cause a greater reason for concern. Without risk, it can become easy to settle into consistency, security and stability.

Wouldn’t you like to know the importance of the risks you face and be able to easily identify them? Strunk’s Risk Manager can help identify risks you may be considering to help grow your business, as well as those risks that may present a greater threat to your organization. It helps to answer the questions:

  • What factors must financial institutions manage against?
  • At this point in time how much risk is each factor creating for us?
  • Do we have adequate management measures in place to manage the inherent risk?
  • And what is the trend – is our situation improving or getting worse?

Risk Manager tracks your risks in a database with fine-grained control over access. It documents your assessment of the inherent risk, the strength of your management of the risk and trend for both. If you must respond to a standards-based set of risks like banking industry requirements or SOC2, explicitly score yourself against these frameworks. The solution will map your policies against control activities to be sure you have appropriate policies in place that address each risk and will allow you to track your risk profile over time.

If you would like to bring together all areas of the risk assessment process into one easy to use format and eliminate your dependency on Excel spreadsheets, invest just 30 minutes to review our solution. Contact us at to learn more.

Reg E Opt-In Communication Options

How are you communicating with your customers that have not yet opted in for Regulation E to choose ATM and everyday debit card coverage for Overdraft Privilege?

When the information is included in the extract file, ODP Manager can determine whether an account has already opted in or has not yet responded with a Reg E election. This allows you to provide specific letter content that tells the appropriate customers that they have an option to authorize Overdraft Privilege for ATM and debit card transactions. The Welcome and Reinstatement letters sent when a limit is assigned or reinstated can include the Consent Form for Overdraft Services and can inform the customer of other options to opt in: online, in person, or by phone.

For your customers that have already opted in for the ATM/everyday debit card coverage, the letters tell them that they already have the benefit of having those transactions covered by ODP.

Once you have assigned a limit do you periodically remind your customers that they have the ability to cover their ATM/everyday debit card transactions using ODP? The ODP Manager software can identify which customers have not opted in and have an OD limit, in addition to other criteria. You can send letters to these customers that explain the Reg E opt-in benefits and opt-in methods and that provide a consent form. This allows you to communicate with these customers on an ongoing basis, not just when the overdraft limit has been assigned.

Please contact Strunk Support at to add the Consent Form for Overdraft Services to your ODP Manager letters or with any questions.

Where has Financial Institution Service Charge Income Gone?

Service Charge income at banks and credit unions across the country is down around 20% for the first nine months of 2020 and there are several reasons why. First, many consumers received stimulus payments from the Federal Government in the second quarter to help spur the economy during the pandemic which has reduced overdraft fees. Second, FIs have increased waives and refunds of service charges to help their consumer checking accountholders. Lastly, debit card interchange has been lower as consumers are spending less during the Covid-19 crisis.

In many cases fee income from the SBA PPP loan program and mortgage originations have help offset the lower service charge income which has been a plus for community FIs. Now bankers will wait and see what losses they might face in their loan portfolio for small businesses that just can’t make it. Bankers are facing trying times and predicting how 2021 will play out is difficult.

Strunk’s Overdraft Privilege and Value Checking programs have been two of the best fee income producers our industry has ever seen. Financial institutions are doing budgeting for 2021 and now may be the time to explore how our programs have helped nearly one third of all banks in the U.S. Both Overdraft Privilege and Value Checking enhance customer service and increase fee income at the same time. Give your customers a choice on how they want their account handled and your bank will reap the benefits just like 1,800 banks across the country have.

Excessive Use Notification Options

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. Non-FDIC regulated institutions also can choose to communicate alternatives to ODP to their customers.

ODP Manager is able to assist you with sending these letters advising your customers of the alternatives to Overdraft Privilege.

There are two options to use these letters. One option is to update your ODP Manager import file to add a field from your core that indicates when the account has qualified by exceeding the threshold. Alternatively, if you are able to identify the appropriate accounts using an existing core report or other method, you can generate the letter as needed as an Ad Hoc letter.

By using ODP Manager as part of your Excessive Use notification process, you can benefit from the software’s letter tracking and retention.

Please contact Strunk Support at to find out more about implementing or using this feature.

The Importance of Understanding your Reg. E Opt-In Form

In 2010 there were changes to the laws and regulations for financial institutions regarding overdraft privilege programs.  Certain Regulation E rules took effect July 1, 2010.  Under these rules, financial institutions must provide notice and reasonable opportunity for customers to opt-in to the payment of automated teller machine (ATM) and one-time point-of-sale (POS) overdrafts provided in exchange for a fee.

Even though this regulation is over 10 years old, there are still misunderstandings from financial institutions regarding the way to present the Reg. E options to consumers, and also the way financial institutions should disclose to their consumers.  Not disclosing Reg. E opt-in correctly to your customers/members could be costly to your institution and also hurt the institutions reputation.  Recently a Bank was hit with $122 million in restitution and penalties to resolve claims that it charged U.S. consumers fees without consent.  The CFPB stated that in some cases the bank required new customers to sign its overdraft notice with the ‘enrolled’ option pre-checked without mentioning the Reg. E service to the consumer.  In other cases the CFPB found that new customers were enrolled in Reg. E without requesting the customer’s oral enrollment decision.

Reg. E opt-in disclosures are highly sensitive matters with regulators and strict compliance is required.  Strunk is the leader in overdraft privilege services and we have a great understanding on how to establish and implement policies and procedures that align with the laws and regulations around Reg. E opt-in. If you have any questions regarding your disclosures or your procedures, reach out to Strunk so we can assist you.

Educating Your Customers and Your Employees

I was recently at a bank and asked the CEO when was the last time you told your customers about a consumer program that they had put in place in seventeen years ago. His answer was seventeen years ago. The same bank had a sign outside and it said “Loan Sale” and I asked him who he was selling his loans to?

During the recent pandemic many bankers are looking at ways to increase fee income even though mortgage origination and PPP loan fees have been through the roof. Telling consumers about the services offered by the bank is one way to generate fee income. Many banks “advertise” their services on a fee schedule and the benefits of the services are nowhere to be found. Ensuring that consumers know about the benefits of the services you offer are paramount to obtaining the level of non-interest income that high performing banks enjoy.

The same CEO answered my question about the last time the employees of the bank had been trained on the same consumer program…17 years ago! So, for the same reason as educating your customers on the benefits of a consumer product your employees need frequent training as well. Not all, but many, banks see a high turnover at the new accounts desk. Generally, the brief training that a new employee gets doesn’t go nearly as far as it needs to in order to increase the cross sale of fee income products and services.

Take a look at each service that you offer to consumers and ask yourself, “When was the last time we marketed the program (educating customers) and when is the last time you trained (educated) your employees on the features and benefits of the service?” Doing so will enhance your ability to generate additional fee income for your bank.