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 support@strunkaccess.com with any questions or to find out more about using this feature.

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 support@strunkaccess.com with any questions or to find out more about using this feature.

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 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?

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.

Strunk Solution Fall 2020 Features

With Strunk’s most recent release, clients can now utilize new features in Risk Assessor, Policy Manager, Controls Manager, Vendor Manager, Skills Manager and ODP Manager. We’ve been busy!

Risk Assessor now provides the ability to pull multiple bank UBPR Data into one single risk assessment. This will simplify assessments for multi-bank holding companies.

Criteria based auto assignment for reader and editor groups is now available in Policy Manager. Users are able to assign specific documents based on physical location or job title, where assignment of a set of policies and procedures could dynamically change based on these rules. We have also adjusted the way the policy acknowledgement is assigned. Admin users have the ability to request that users read a policy at a configurable number of days in the event that a policy is updated throughout the year, rather than just every 365 days. Users will be notified of necessary policies to review via email.

Controls Manager now supports notification of the group owner rather than simply the control owner. Alerts will be triggered any time a significant change or update is made to a control.

Clients will be excited to see the improvements to Vendor Manager reporting. Users can sort by a customized list of vendor types, vendor risk level and renewal year within all summary reports. Reports will also include whether or not the vendor survey has been completed and if not, what the current status is.

Skills Manager exams have historically been comprised of multiple choice or true false questions. We now support the option to have an open ended comment for specified questions.

Lastly, ODP Manager provides the ability to mark old status codes as inactive or deleted so they no longer show on reports, such as the Status Tracking Report.

If you would like more information on any of Strunk’s new features or products, please contact us at 800.728.3116 or support@strunklp.com.

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 support@strunkaccess.com 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.

Create Letters On Demand with ODP Manager Ad Hoc Templates

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

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

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.