Reg E Opt-In Communication Options

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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 support@strunkaccess.com 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?

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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

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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 support@strunkaccess.com to find out more about implementing or using this feature.

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

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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

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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.

Create Letters On Demand with ODP Manager Ad Hoc Templates

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ODP Manager allows you to easily generate your organization’s Collection or Custom letters based on specific criteria that is updated by importing your core extract file each day. There are situations where these criteria may not always be sufficient for each and every letter that you need to send.

What should you do if there is a letter that you want to send that doesn’t meet your existing letter criteria? Have you ever needed to send an Account Close letter to close an account before your standard number of days overdrawn? Do you have other ODP related letters that you’ve been sending manually?

Strunk Support can configure Ad Hoc letters within ODP Manager for your institution. This flexibility lets you send the letter as needed – it doesn’t rely on an account event to trigger it. When you need to generate the letter on demand, simply enter the account number and the letter will prefill with the information from the software, just as it would in a standard template. Once it is generated, ODP Manager tracks and retains the letter just like your Collection and Custom letter templates.

Please contact Strunk Support at support@strunkaccess.com to make the most of your ODP Manager solution and learn more about implementing or using this feature.

Reviewing your overdraft privilege program during a pandemic

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With the Covid-19 pandemic having an enormous effect on a financial institution’s overdraft privilege program, this is a great time to review your existing program to make sure it is running as efficiently as possible.  Financial institutions pointed to government relief efforts, increase in unemployment benefits and the decrease in discretionary purchases that had a negative impact on overdraft privilege programs.  Even with these obstacles in our way there are still ways to make sure financial institutions maximize their fee income from their ODP program.

  1. Clean up accounts to prevent creep-age.  We find that most financial institutions, over time, experience a downward trend in percent utilization, which has a significant negative impact on fee income. By using reports that are produced in Strunk’s ODP Manager software, financial institutions will be able to gain a great understanding on how each account is performing.
  2. Evaluate your institution’s Reg. E opt in rate. The Federal Reserve Payments Study shows that roughly two-third of all transactions are done by debit card. Making sure customers understand what opt-in means for them and what happens if they don’t opt in is essential.
  3. Review how overdraft waives/refunds are being handled inside your financial institution. Waives/refunds are an area with two issues: Reduction in income fee and possible compliance issues.

There is no better time to do a complete review of your overdraft privilege program than during the Covid-19 pandemic.  Strunk can perform a checkup on your program to help with compliance and profitability while also training your employees to ensure consistency within the program.

Overdraft fees have plunged 49% due to COVID-19 pandemic

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At Strunk, we have been focused on assisting clients with an unprecedented struggle these past few months due to the current COVID-19 pandemic. Overwhelmingly, the second quarter has been a very difficult time for overdraft/NSF fee income. According to a recent study published by S&P Global Market Intelligence overdraft/NSF income is down 49% industry-wide in Q2 2020.

Further, the study goes on to explain some of the reasons behind the significant downtown. As we have expected, drop in consumer spending and liquidity created by government stimulus money are the largest contributors. Many financial institutions have also reported significant fee waivers in an effort to help account holders impacted by COVID-19.

Dan Roderick, CEO at Strunk said, ‘what happens from here is difficult to forecast given the unprecedented nature of the cause of this particular economic downturn’. Most analysts and bankers say they do expect a rebound in consumer spending behavior in the third quarter as the economy continues to reopen. However, it is expected that the deposit fee line item will remain below historical trends. One thing we can be sure of is that times have changed, and we are in uncharted territory.

We are all aware that overdraft programs are consistently a hot topic amongst regulators and at Strunk, we’ll make sure your program is fully compliant, even during an economic situation like we are experiencing. Compliance is more important than ever and we are here to help. If you have questions regarding your current program please do not hesitate to contact us at info@strunkaccess.com.

Customized Reporting Options in ODP Manager

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Strunk’s ODP Manager includes a comprehensive suite of reports designed to help you monitor your ODP program. Reports are available in Excel or PDF format or can be viewed on screen. For each report you can apply individual data filters and export the filtered results.

PDFs of selected reports can be retained within the hosted software using the Archive Reports feature. After each import a copy of the specified report is saved within ODP Manager.

Your standard reports and Account Inquiry groups are configured based on Strunk’s standard recommendations. What are your options to customize your information?

Segment which information is displayed further by utilizing Query Groups. These client-specific groups limit your results to accounts that only meet your desired criteria. They can be added to an existing report or they can be used in Account Inquiry.

If you need more control over which data fields are displayed, you can use Custom Queries. They allow ODP Manager to specify not only which accounts are included but also the data columns that are displayed. If there is an institution-specific report that you will generate on a regular basis, a Custom Query may be your solution.

Please contact Strunk Support at support@strunkaccess.com to find out more about implementing or maximizing the usage of these features.

Clarification on how to handle “Force Pay” items in an ODP program

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Financial Institutions encode items with a special transaction code to ensure payments are received before other items clear an account. The codes are used for a variety of reasons. As long as you make a deposit or have enough money in your account to cover the transaction, you don’t have to take further action.  A “force pay” debit is a special transaction code used by the financial institution to insure that a debit purchase clears an account first. An example of a “force pay” debit card transaction is if a consumer is at the gas pump and that consumer has $5 in their checking account.  Once the consumer swipes their debit card at the gas pump the merchant receives an authorization for $1.  The consumer then puts $50 worth of gas in their vehicle.  In this scenario the debit card transaction is paid and the financial institution is not allowed to return items to the merchant that are presented for payment.

How should financial institutions handle these transactions to make sure that they are in compliant with all regulatory requirements.  “Force Pay” debit card or ATM items that overdraw an account cannot be charged an overdraft fee if the account does not have an overdraft limit and the consumer has not “opted in” for Regulation E purposes.  Strunk met with David Stein, co-author of Regulation E, at the CFPB and he clarified for us that institutions should not be charging fees on consumer accounts if the bank would not normally authorize the electronic transaction. These are referred to as “no pay” accounts in CFPB terms. If a new customer checking account is in the waiting period before a limit is assigned, or if an accountholder’s limit has been taken away for some reason, you cannot charge an overdraft fee for these force-pay caused overdrafts, even if that customer has “opted in”. The basis for this position is to address any potential Unfair, Deceptive and Abusive Acts and Practices (UDAAP) application if a customer has no potential to receive benefit from your overdraft program.

An independent certified public accountant has examined Strunk’s operations and found them to be in compliance with the AICPA’s Trust Service Principles. It was determined that Strunk meets the Security, Availability, Processing Integrity, Confidentiality, and Privacy criteria for SOC 2 established by the AICPA.