Using ODP Manager to Review Your Overdraft Privilege Program Information

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Strunk’s hosted ODP Manager software is updated daily with information contained in an extract file generated from your core system. After the daily import, users can generate letters, review management reports, and access additional information to effectively manage a compliant ODP program.

Percent of accounts with an assigned overdraft limit and percent of accounts opted in for Regulation E are important metrics to monitor for the success of an ODP Program. This importance is highlighted on the Dashboard which is displayed after each ODP Manager login. Trends in the Percent with Limit and Percent Opt In are shown over several months. Monthly benchmarks for the Percent with Limit and Percent Opt In are compared to other Strunk clients by the 25th, 50th, and 75TH percentiles. Overdraft Fee and Overdraft Limits are also benchmarked against other Strunk client percentiles. The Utilization Analysis report and the Opt-In Impact report allow users to further review the percentages summarized by branch and by deposit product.

On reports that include account-level details, users can apply filters or select groups to further examine data. Once the filters are applied, the filtered results can be exported to PDF or Excel for additional review or discussion. Reports that show account details include Overdraft Aging, New Accounts, ODP Status Tracking, Fresh Start Tracking, and ODP Heavy Users.

In the Account Inquiry area in ODP Manager, users can apply column filters and groups. If users need to create a list of accounts meeting certain criteria, Account Inquiry gives them the flexibility to build the list and export it to Excel. This flexibility allows users to access all the data included and mapped from the daily import file.

ODP Manager also allows users the ability to search for specific events that occur during a date range. This can help users compile a list of letters sent, OD limits assigned or removed, or Reg E opt ins or opt outs.

If you have any questions about ways to view or export the data in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Save Reports Automatically After Each Import

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The hosted ODP Manager software includes a comprehensive suite of standard reports. These reports should be reviewed periodically to assist with Overdraft Privilege program management and maintenance. These reports are updated after the daily extract file is imported into ODP Manager. Reports can be viewed in the browser or can be exported to a PDF or Excel file.

In addition to allowing users to review reports for the last seven as of dates in the browser, ODP Manager also offers a Report Archive feature. This allows past reports to be automatically retained so that they are available for future review, analysis, or comparison as needed.

Institutions can select which reports they would like to archive. After each import succeeds, the selected reports are saved as a PDF and stored within the ODP Manager software. The reports can be retrieved from the Archived Reports section in Reports and are organized by as of date. If users would prefer to download the reports to store on a network drive, the Archive feature can be configured to allow a Download Report Archive link instead.

If you have any questions about setting up or using the Report Archive feature in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Strategy to Combat Bank Service Charges Under Attack

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Bank fee income has come under attack once again by the regulators and what can you do about it? Four fee income producing products that all banks offer will be curtailed with recent changes to regulatory guidance.

  1. The banking industry has charged fees for returned checks on consumer accounts for as long as most of us have been in banking. Some regulators don’t like banks charging for second presentment of a returned check even though that practice is fully disclosed. Since it is difficult to determine if an item is being presented a second time, some banks have discontinued charging for NSF items.
  2. Getting consumers to opt in for debit card caused overdrafts has been around since July 2010 as required by the Federal Reserve. The nearly 15 year old regulation requires banks to send a confirmation when a consumer opts in. Now the regulators want you to a) get a signature on the A-9 form or b) record all calls where the consumer opts in for the service. Reducing the number of opt-ins will substantially decrease your bank’s fee income.
  3. Now the CFPB wants to limit what your bank can charge for an overdraft or NSF item. The maximum fee is $5 or whatever it costs you to process the item. Most community banks charge $25-$35 per NSF item so this will once again substantially reduce fee income.
  4. Lastly, six months ago there was a Federal Reserve proposal to cap the debit card interchange that your bank receives. Likewise, there is a Credit Card Competition Act that the Senate is currently looking at. The result of these actions would reduce interchange and or swipe fees for banks.

Since 2011, Strunk’s Secure Checking program has helped hundreds of banks provide features to their consumer checking accounts for a small monthly fee. Consumers like the benefits offered and they don’t mind paying for them. In many cases those same consumers are paying quite a lot more elsewhere. Much like the Overdraft Privilege strategy, Secure Checking generates a considerable amount of customer loyalty and goodwill while the bank increases fee income by at least $50 per account per year.

Contact Strunk at 800.728.3116 or info@strunkaccess.com to find out more about our proven strategies to increase income. Have a great 2025!

Reporting on Charge-Off Items and Recoveries

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ODP Manager generates the Account Closed letters necessary to notify customers when accounts are closed and charged off due to unpaid and outstanding overdrafts or due to a default on a Fresh Start Repayment Plan for outstanding overdrafts. Closed accounts typically no longer appear in the daily extract file imported into ODP Manager; however, users are still able to manually track charged-off accounts and recoveries in the hosted software.

Once the account is charged off, a user can create a charge-off item that includes the date, charge-off principal, charge-off fees, charge-off reason, and item status. Notes can be added to the item at the time of charge-off and notes can continue to be updated throughout the recovery process. As recoveries are made, they can be entered in ODP Manager. This will reduce the charge-off balance remaining.

The C/O Items and Recoveries summary page can be accessed under the Account Inquiry menu. This page, by default, displays the charge-off items for the last year. If a different timeframe should be displayed, institutions can request a customized default timeframe. The start and end date for the charge-off items can also be changed by the user at any time.

The summary reporting displays basic account and charge-off information and can be exported as an Excel file or as a PDF. The PDF format also includes overall totals and totals by branch.

If you have any questions about using the Charge-off Items and Recoveries feature in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

Strunk Helps Banks Make More Money

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For the past 31 years, Strunk has helped financial institutions make more money by providing services to their customers that they want and need. The Strunk Overdraft Privilege program was implemented in over 1,800 banks across the country and it provided a much needed service. Banks typically charge the same fee whether they pay or return an insufficient funds item. Who would want their checked returned to the merchant? Our hosted ODP solution helps with collections and tracking the success.

Since 2011, Strunk’s Secure Checking program has helped hundreds of banks provide features to their consumer checking accounts for a small monthly fee. Here again consumers like the benefits offered and they don’t mind paying for them. In many cases those same consumers are paying quite a lot more elsewhere. Much like the Overdraft Privilege strategy, Secure Checking generates a considerable amount of customer loyalty and goodwill while the bank increases fee income by at least $50 per account per year.

Pricing commercial loans to meet the customer’s needs and to meet the profitability goals of the bank is yet another way Strunk helps banks make more money. Most banks typically price loans on risk, term and type of loan. But, should the size of the loan and fees be considered? Having a tool to help your bank win more deals and price smaller loans to ensure profitability can increase net interest income by 25 bp or more.

Contact Strunk at 800.728.3116 or email at info@strunkaccess.com to find out more about our proven strategies to increase income. Our solutions are easy and inexpensive to implement. Have a great holiday season and may 2025 be a great year for banking!

Save Consumer Reg E Opt-In and Opt-Out Documentation

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In order to provide evidence that consumers have provided confirmation to opt in for ATM and everyday debit card transactions, Strunk recommends that financial institutions have consumers sign or initial the A-9 form (Consent for Overdraft Services) for opt-ins by mail or in person, record and retain consumer opt-ins by phone, and store opt-in transactions and electronic signatures for consumers who opt in online or by mobile device.

ODP Manager has added the capability to help institutions attach and organize this information in the hosted software. Each account will now have an Attachments tab in the account view which will allow users to manually upload or link the proof of a consumer’s Reg E election. For each attachment, users will select the Type of attachment (Opt In / Opt Out / Other), the attachment Source (Scan / Recording / Other), and the Attachment Date. PDF, image file, and audio file formats can be attached and saved. Once saved, these files can be viewed or listened to when viewing an account’s attachments.

For institutions that use Strunk’s online opt-in process, ODP Manager now will display open accounts that match the consumer’s submitted partial account number(s). Users can use the displayed name, address, phone, and email information to identify the correct account number to update the Reg E election in the core accordingly. Once the ODP Manager user has identified the matching account number, the transaction and electronic signature record can also be linked to the account in the hosted software and the verification will display on the Attachments tab.

Strunk has added these new options in ODP Manager to provide financial institutions with additional methods to organize and track their Reg E-related documentation. If you have any questions about using the new Attachments feature in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com for more details.

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.

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.