Streamline Hosted ODP Manager File Import

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For ODP Manager to obtain updated account information, an import of the ODP Manager extract file from the core system must be committed each day. Although many institutions manually import the file, there is an option for the upload to occur automatically overnight.

If your core is able to generate your updated extract file automatically to a specific file location at your institution, Strunk can help you set up the Automatic Upload process to run overnight. When your users log in at the beginning of their workday, the updated information is already available, and your users can proceed directly to generating letters and reviewing daily reports.

To use the Automatic Upload, there is a one-time setup process. First, the client that performs the upload will need to be installed. Second, the configuration file needs to be updated with institution-specific information like the user performing the import and the file name. Finally, a scheduled task is created that will run overnight at your institution – initiating the import process at a scheduled time after the close of business.

After the import process completes, users will be notified by email if the process succeeded or failed. Email notifications can be sent to a group email address or to specified individuals. Users will still retain the opportunity to manually import the file. This allows users the option to proceed with a manual import to review the Preview screen for troubleshooting. It also allows them to manually import the file while additional changes may be made to the automatic upload process.

Implementing an Automatic Upload should streamline the file import process and should allow your users to focus efforts on the daily tasks of letters and report review.

If you have any questions about setting up and using the Automatic Upload process in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Important Regulatory Announcement

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As you may know, on September 17, 2024 the CFPB issued a circular regarding ‘Improper Overdraft Opt-In Practices’. This circular outlines the CFPB’s guidance related to obtaining Reg E opt-in from consumers. In short, it represents a significant change to the interpretation of Reg E Opt-In requirements.

Since Reg E requirements took effect on July 1, 2010, the practice for obtaining opt-in outlined by Strunk has passed muster with every regulatory authority including the FDIC, OCC, Fed, and NCUA. Over that entire period of time – over 14 years – we have never had a client cited for not properly obtaining Reg E opt-in. The foundation of this practice was essentially twofold – FIs were to provide the consumer with the Reg E A-9 form and then follow up with a notice produced from ODP Manager sent to the consumer confirming their opt-in and once again telling them they have the option to opt back out. The A-9 was to be provided to every consumer upon account opening or request to opt-in. The confirmation notice history is maintained in ODP Manager.

Evidently, after 14 years, the CFPB has determined that in order to provide evidence that the confirmation was obtained from the consumer, the A-9 form must be signed or initialed. They also outline that opt-ins provided over the telephone must be recorded and opt-ins obtained online or via mobile app must be stored and signed with an electronic signature. The specific language in the CFPB circular is as follows:

  • For consumers who opt into covered overdraft services in person or by postal mail, a copy of a form signed or initialed by the consumer indicating the consumer’s affirmative consent to opting into covered overdraft services would constitute evidence of consumer consent to enrollment.
  • For consumers who opt into covered overdraft services over the phone, a recording of the phone call in which the consumer elected to opt into covered overdraft services would constitute evidence of consumer consent to enrollment.
  • For consumers who opt into covered overdraft services online or through a mobile app, a securely stored and unalterable “electronic signature” as defined in the E-Sign Act (15 U.S.C. 7006(5)) conclusively demonstrating the specific consumer’s action to affirmatively opt in and the date that the consumer opted in would constitute evidence of consumer consent to enrollment.

Although the CFPB technically only has supervisory authority over FIs with assets in excess of $10B, and no regulator has the authority to issue new regulations, in the current environment it is our view that it is highly likely that each of the respective regulatory authorities for financial institutions will adopt this same ‘guidance’ and administer their examinations accordingly. That being the case, we urge you to adopt the approach outlined in the three bullets above when obtaining consumer opt-in for Reg E. Specifically, what this means is:

  • For consumers who opt in via postal mail or in person – have them sign or initial the A-9 form:
  • For consumers who opt in via telephone, make sure your calls are recorded, and those recordings are retained.
  • For consumers who opt in online or via mobile device, store the transaction along with electronic signature. Strunk supports an online opt-in process, which can be tracked within ODP Manager. Please contact us if you would like us to configure that capability for your institution.

With respect to existing consumer account holders, the same rules all apply. So, if you do not have the physical evidence outlined above for consumers who currently are coded as opted in for Reg E, you must contact those consumers to obtain the affirmative consent outlined above. If those consumers do not provide the necessary confirmation, we would recommend removing their Reg E opt in from your system and discontinue approving their Reg E overdraft transactions and charging fees.

Use ODP Manager Data to Generate Letters as Needed

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The hosted ODP Manager software includes three types of letter templates: Collection, Custom, and Ad Hoc letters. Collection letters are sent to accounts that are currently overdrawn with a negative balance. Custom letters are focused on communicating Overdraft Privilege Program-related information to customers. Ad Hoc letters allow ODP Manager users to generate letters as needed without relying on an account event to trigger the letter.

By using Ad Hoc letter templates, institutions can eliminate manual processes of creating and addressing letters outside of ODP Manager. To generate the letter, users will need a list of accounts that should receive the letter template. Each letter template can be generated one account at a time, or multiple account numbers can be entered at once. The customer’s name and address information will populate from the most recent ODP Manager extract file imported. Additional letter data fields can also be populated with information stored in ODP Manager. Once generated, the letter will be retained inside the hosted software just like Collection letters and Custom letters.

If accounts are closed and charged off before the standard number of days overdrawn, users will need to generate an Account Closed letter to appropriately notify the customer. There also may be some specific situations that require ODP-related letters that are not covered by the standard Collection and Custom letter templates. Ad Hoc letters can also be used to generate a customer’s Fresh Start Repayment Plan agreement. The inherent flexibility of the Ad Hoc letter template feature may allow institutions to accommodate all Overdraft Privilege Program-related letters – not just letters included in the standard Collection and Custom letters.

If you have any questions about setting up and using Ad Hoc letters in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Today’s Overdraft Environment

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In today’s financial environment, having access to emergency funds is more crucial than ever. Many individuals are struggling to cover everyday expenses, and overdraft privilege can offer reassurance to customers who require fast access to short-term funds. Consumers, especially those who use overdraft services, continue to show a strong understanding of overdrafts and the options available to them. Consumers would much rather have their transactions paid for than returned. In either case, the financial institution will charge a fee. In the last two years, just over half of consumers have needed immediate access to funds to pay their bills. Political leaders tend to believe that overdraft privilege only affects lower-income consumers, but consumers earning between $100,000 and $150,000 also need access to short-term emergency funds. This is not a matter of wealth, but rather of having access to available cash. For consumers with accounts at financial institutions, having access to cash when needed is crucial. The benefit of not paying a fee unless they use the service is the type of access they are looking for.

Half of all account holders will need help with liquidity at some point. Consumers can’t predict when they will need access to emergency funds, but they want to be certain that if a crisis arises, it will not have a long-term effect on them or their credit. More than 60% of overdrafts come from consumers who intend to use the service and appreciate the value it adds to their checking account. Consumers are looking for a solution without a long-term commitment, such as credit card debt or a personal loan, and overdraft privilege provides that to them. Having access to additional funds when a consumer is in need is highly beneficial, and they do not want to experience any reductions in their ability to use the service. Approximately 30% of consumers use overdraft services, indicating a sustained demand for this offering. It is crucial for financial institutions to provide alternatives within their framework, such as Overdraft Privilege, Line of Credit, and a transfer from another account so that consumers can manage their fees and protect their income. Additionally, a repayment program is available to assist consumers who are having difficulty with their budgets, providing them with extra time to repay their overdraft limit. Strunk offers Overdraft Privilege consulting services and the best software to ensure your Overdraft Privilege program is an ongoing success.

Leverage Extract File Date Fields to Filter Results

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The daily extract file imported into hosted ODP Manager includes many fields that may assist with managing an institution’s Overdraft Privilege program. These fields are used to show letters due and also to populate the standard suite of reports included in ODP Manager. In addition to these purposes, institutions may also benefit from using this data to display filtered results of accounts that share specified criteria. These additional filter options may facilitate monitoring of accounts in specific areas of interest.

The first step to leveraging additional filter and group options is to decide which fields and criteria should be applied to the accounts. Once determined, there are three main areas in ODP Manager that are able to use the additional filter groups: account-level Reports, Account Inquiry, and Custom Query.

Users can apply the filters as needed by typing the desired criteria in the filter boxes displayed below the ODP Manager header rows. If users are entering the same criteria regularly, it may be more efficient to request the creation of an institution-specific query group. Once the individual column filters have been applied or the query group selected, users can view the information in the browser, export the filtered results to either Excel or PDF in Reports, or to Excel in Account Inquiry and Custom Query.

In Account Inquiry, users can choose from three different views to select which extract file fields are available for filtering or export. Both the Default View and Original View display different sets of commonly used fields. The All Fields View displays all fields mapped and available in the hosted software.

If an institution’s users need to limit not only the results displayed but also specify which columns are included, a Custom Query can be created. This Custom Query can be downloaded daily (or as needed) to Excel and will include the accounts that meet the specified criteria.

If you have any questions about setting up additional filter groups in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

How to Replace Lost Fee Income for Banks?

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Strunk has helped over 2000 banks increase their bottom line from a variety of income producing programs that started in 1993 with their Overdraft Privilege program. The service benefited both consumers and banks and although income is down from NSF/OD fees it still remains popular even after tremendous regulatory scrutiny.

In 2010, banks were required to obtain consumer consent before charging an overdraft fee for a debit card transaction that overdrew the account. Service charge income went down significantly. In 2011 FDIC regulated banks had to notify consumers after every 6th overdraft charge in a rolling twelve month period. Service charge income went down again.

More recently banks have discontinued charging NSF fees if their core processor can’t determine if the item had already been presented. Some banks have discontinued allowing consumers to overdraw their account and they have eliminated overdraft fees. To total all of these changes up our industry has seen more than a 50% drop in service charge income in the past 15 years.

What can a bank do about it? Strunk’s Secure Checking program allows consumers to get highly sought after services from their bank while paying a small monthly fee for their checking account. Banks see a net increase in income per checking account of $50 per year. Strunk’s Loan and Deposit Pricing tool will help banks increase net interest income by at least 25bp. For a $100M loan portfolio that is $250K per year.

Strunk is here to help banks make more money. Contact Strunk at 800.728.3116 email at info@strunkaccess.com to learn more about income programs offered by Strunk. You will be glad you did.

Regulation E Option to Opt In Online

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Strunk’s ODP Manager recommended custom letter templates include copies of the Consent Form for Overdraft Service. This allows consumers that have not already opted in the opportunity to opt in to authorize and pay overdrafts for ATM and everyday debit card transactions. Customers should have the option to opt in or opt out of Reg E by phone, by mail, or in person. If available, consumers should also be able to opt in to Reg E electronically.

If a financial institution’s online banking does not already offer customers the ability to choose to opt in or opt out, the hosted ODP Manager software can provide an electronic option. An online form will be created that matches the content in the ODP Manager letter templates. Once created, the form will be linked on the institution’s website. Customers can electronically complete the form to consent to opt in to or opt out of the ATM and everyday debit card coverage. After submitting the form, both the customer and a designated institution email address will receive a confirmation of the request.

After the request is submitted, ODP Manager users will regularly review new requests tracked in ODP Manager. The list of requests can be exported so that the accounts can be updated appropriately in the core system. The hosted software is able to identify new responses that have not yet been downloaded. Once downloaded, the software still retains the prior responses within the ODP Manager software.

If you have any questions about setting up online Reg E Opt-In and Reg E Opt-Out forms in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Excessive ODP Use and Alternatives to ODP

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The hosted ODP Manager software includes a letter template that allows financial institutions to inform customers of alternatives to fee-based overdraft coverage. These letters are sent to customers that have demonstrated excessive consumer Overdraft Privilege activity.

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.

Alternatives to ODP could include an Overdraft Protection credit line or an Overdraft Protection transfer from another account with the financial institution. The letter template includes details related to line amounts, charges, and fees so customers can make an informed decision about how best to cover overdrafts.

Letters can be generated based on information included in the extract file. If the file includes data that indicates when an account has met the qualifications for the letter, hosted ODP Manager can automatically show when the letter is due. If the data cannot be added to the extract file but accounts that qualify can be identified by an existing core report or other method, the letter can be generated as needed by account number as an Ad Hoc letter. Once generated, the letter is tracked and retained within ODP Manager.

If you have any questions about sending Excessive Use Notification letters in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

ODP Manager: Import Events and User Events

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The information displayed in ODP Manager is provided by an extract file from an institution’s core system. This file is updated after close of business and is imported daily into ODP Manager. Once the import has occurred successfully, the letters due and reports are updated with the information for the current as of date.

A benefit of the hosted ODP Manager software is the advanced history tracking. This feature allows users to view and search for recorded events by account number or date. There are three main types of events that are stored within ODP Manager: import events, letter events, and user created events.

Import events are recorded at the time an import of the extract file is successfully processed. Events are identified by comparison of the current as of date’s file to the last file imported. Accounts are updated to note if accounts are now closed, are overdrawn, or now in good standing. If an overdraft limit is assigned or removed or if an account opts in or opts out for Regulation E, an event is also created in the account history.

As part of the daily tasks in ODP Manager, users will generate letters that are due. As letters are generated, a PDF of the letter is retained in the event history. The letter type, template name, and date are also recorded.

Users also can create events as needed. Comments allow users to make account notes that can be viewed by all hosted software users. Reminders allow not only notes to be added, but also allow a due date to be assigned to the item for future follow-up. Both notes and reminders can include attachments. Repayment plans can be added to generate Fresh Start agreements and to track payments made towards the repayment schedule. For accounts that have charged off, users can create a charge-off item to track recoveries and to streamline charge-off reporting. All user-created events can be viewed and updated by all users with access to ODP Manager.

Once events are tracked in ODP Manager, they can be searched by account number or by date or date range. Individual account information can be exported to PDF and events that occur in a specified date range can be exported to Excel.

If you have any questions about event information accessible in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

Standard Reports Available in ODP Manager

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Strunk’s ODP Manager hosted software includes a standard suite of reports that summarize the information from the most recent extract file imported. These reports can be used by management and by daily users to analyze ODP Program performance and assist with program compliance.

The Summary Report includes totals for overdrawn and not overdrawn accounts, number of accounts by ODP Status Codes, and recommended totals for overdrawn accounts reserve by branch and product. A trend graph displays the accounts with limit, the used commitment, and aggregate privilege over time. NSF and OD Fees and Refunds are also displayed in bar charts. Additional overdrawn account information and reserve information is summarized in the Overdraft Detail Report and the Overdraft Aging Report.

The Overdraft Aging and New Accounts Reports show individual accounts that should be reviewed daily to determine the assignment and removal of overdraft limits. The Fresh Start Tracking Report allows users to monitor accounts with Fresh Start Repayment Plans. The Letters Printed YTD report allows your institution to track the total number of letters and which letter templates are generated by month and year.

The Status Tracking and Heavy OD Users Reports show accounts that do not currently have overdraft limits assigned. These accounts should be reviewed at least quarterly to determine if the accounts now meet the qualifying criteria to be assigned an OD Limit. Consistent review of these accounts will help maintain a high percentage of eligible accounts in the Overdraft Privilege Program.

The Utilization Analysis, Opt-In Impact Analysis, and LOC/Sweep Analysis reports focus on performance analysis.  These reports include a Branch Summary and Product Summary table. Monitoring the percent of accounts with overdraft limits and the percent of accounts opted in for Regulation E is very important to maintaining or improving ODP program performance. The LOC/Sweep Analysis Report allows comparison of the number of accounts with ODP to the number of accounts with other options to cover overdrafts, such as lines of credit or sweeps from other deposit accounts.

If you have any questions about reports available in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

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.