Hosted ODP Manager and Individual Account Information

ODP Manager includes the ability to review the account level information for each account that has been imported into ODP Manager from your daily extract file. By using the Account Inquiry section in the hosted software, an institution’s users can view multiple accounts or details of a single account.

In Account Inquiry, users can select the view that contains the necessary columns and select groups or apply filters so only the desired accounts are shown. Once the list of accounts has been created, the data can be exported to Excel to be saved or for distribution. This information can be used to supplement ODP Manager’s existing standard reports. It also may be an alternative to creating custom reporting in the core system about accounts managed in the ODP Manager software.

Account Inquiry also allows access to the information for a single account. Since historical events are retained in the ODP Manager software, details can be viewed for both open and closed accounts. To manage the account, users may need to review an account’s contact information, event history, reminders, or comments. If the account is under a Fresh Start Loan or has charged off, users may need to view the related repayment schedule or charge-off items and recoveries.

Leveraging the information already included in ODP Manager may make it easier for your users to review and manage accounts efficiently. Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more about using Account Inquiry.

 

What we know now about overdraft privilege

Overdraft privilege appears to have been widely covered in the media over the past 12 months.  We wanted to address some of the most recent worries that have been raised in these news pieces because overdraft privilege programs have received a lot of negative attention and inaccurate information.

  1. Overdraft Privilege has not undergone any new regulatory changes: In July the U.S. House Committee on Financial Services passed the H.R. 4277, the Overdraft Protection Act. This legislation has been presented by Congresswoman Carolyn Maloney (NY) every year since 2009 to the House and has never pass the Senate.  Although the banking industry has evolved significantly since the initial version of the bill was introduced in 2009, its language has remained stagnant and does not take into account the realities faced by modern consumers.  Since the initial version of the bill was introduced, financial institutions have made considerable adjustments to their overdraft programs to be more consumer friendly.  Because overdraft privilege “remains one of the few short-term liquidity products available to consumers within the well-regulated, well supervised banking system,” financial institutions are expanding the flexibility of their product offerings to meet consumer demand and are emphasizing choice in an increasingly competitive market.  This is why it will be the same as the previous 10+ years in that this bill won’t go any farther than it already has.
  2. Almost all financial institution still have some sort of Overdraft Privilege Program: August 2021 we started hearing about financial institutions that were eliminating their overdraft fees. What we found that most financial institutions that were eliminating overdraft fees were doing it for specific accounts.  Most of these financial institutions created a ‘checkless’ checking account for consumers who did not want overdrafts/nsf on their checking accounts.  With these accounts, consumers would not have access to checks and also be limited on what they can do with their debit card transactions, providing no overdraft/nsf transactions. Unfortunately, these accounts are not always free accounts.  It seems most financial institutions are charging Monthly Maintenance fees for this account and some financial institutions are even charging excessive transaction fees.  This type of product is not for everyone because there are consumers that still want access to checks and don’t want to pay a monthly maintenance fee for their checking account.   This past year, through surveys we learned that consumers understand overdraft privilege, they would much rather their item be paid instead of returned, consumers believe od fees are reasonable, and they don’t want to see any reduction to their overdraft access. Overdraft Privilege is still a better product for consumers and consumers still want access to an overdraft limit.
  3. Regulatory groups have started to really focus on NSF fees and Re-Presentments: August 2022 FDIC released Supervisory Guidance on Multiple Re-Presentment NSF Fees. The FDIC stated that it is issuing the guidance because of its observations in consumers compliance exams where consumers are charged multiple NSF fees for the same transaction when a merchant resubmits the transaction for payment. The FDIC has also observed that some institutions’ disclosures did not adequately describe the institution’s re-presentment practice. Luckily for Strunk clients we have been sensitive to this issue for quite a while. In the Spring of 2020 Strunk issued suggested language for checking account agreements to all of our clients to provide enhanced disclosure regarding an arbitration provision.  Also, Strunk’s Overdraft Privilege Service Policy has always included specific language regarding re-presentments. These two things provide for a very strong argument that our client financial institutions are already handling disclosure regarding this issue properly.

Even though there have not been any changes to overdraft regulations, some financial institutions felt political and regulatory pressure to make changes to their overdraft privilege program.  We know that overdraft privilege is a much better service for consumers than returning their items.  Elimination of overdrafts, resulting in more payments being returned, which can lead to repercussions for the consumer such as late payment fees, merchant fees, and potential negative impacts to their credit.

Document Retention in ODP Manager

As part of the daily use of the hosted ODP Manager software, users may generate or review documents such as letters or reports. ODP Manager includes features that make it easier for these documents to be retained for future reference.

Each time a user generates a letter, a PDF of the letter is saved and linked to the account’s event history. This makes it easy for letters to be retrieved by customer account or by date and letter type.

The ODP Manager solution allows you to export and save your institution’s reports as Excel or PDF files. The most up-to-date information is always viewable under the Reports section. Users are also able to access reports from the most recent seven As of Dates.

If past reports are retained for additional analysis, there is an alternative to manually exporting and saving copies of reports. If requested, Strunk can set up a Report Archive that includes any of the reports available in ODP Manager. The requested reports will be automatically archived after each import.

Once the Report Archive has been created, PDF files are automatically saved within ODP Manager after each import of the daily extract file. Archived reports are organized by As of Date and retrieved from the Archived Reports section. If your institution would rather download the reports from the archive to save to a network drive instead, a Download Archives link can be set up as an alternative.

Let the document retention features in ODP Manager streamline your ODP letters and report retention! Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more about using these features.

Monitor Fresh Start Loan Repayment Schedules using ODP Manager

After the daily import of information in the extract file from your core processor, the Letters, Reports, and Account Inquiry sections of ODP Manager are updated. In addition to this updated information, the hosted software also allows you to add additional information about repayment plans manually to facilitate monitoring of account’s Fresh Start Loan payments.

If you choose to use the Fresh Start Loan repayment plan feature, after completing your Fresh Start Repayment Plan assessment and approval process, you can enter the repayment schedule information directly in ODP Manager. The data in this schedule can be used to fill in your Fresh Start Loan agreement and will make it easier to generate the document to be signed by your customer.

Once the repayment schedule has been created, Strunk’s Reminder feature will create reminders for each payment. Your Strunk software users will be able to monitor each day whether any FSL payments are due and can then check your core system to see if the payments have been made as agreed. After verifying that a payment was received, your users will track the payment date and amount in the ODP Manager software. The repayment schedule is then updated to show the payments made and the outstanding balance on the Fresh Start Loan.

Repayment plans can be viewed not only for each account, but also on a summary list that can be exported to PDF or Excel for reporting purposes. The repayment plan tracking feature in ODP Manager can help your users streamline Repayment Plan Agreement generation, Fresh Start Loan payment tracking, and repayment plan reporting.

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

Following Up with Frequent Overdraft Privilege Users

Financial institutions are expected to monitor excessive consumer Overdraft Privilege usage to inform customers of additional available options for overdraft protection. These options could be an Overdraft Protection Credit Line or an Overdraft Protection Transfer from another account with the financial institution.

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.

ODP Manager can assist with sending letters advising your customers of the alternatives to Overdraft Privilege. If the ODP Manager import file includes data from the core system that indicates when an account has qualified for the letter by exceeding the threshold, the hosted software can automatically show when a letter is due to be sent. If the data is unable to be added to the extract file but qualifying accounts can be identified from an existing core report or other method, a letter can be generated, as needed, as an Ad Hoc letter.

Once the letter is generated, the letter is tracked and retained within the ODP Manager application.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more about using ODP Manager’s Excessive Use Notification letter.

ODP Manager Account History

One major benefit of the hosted ODP Manager software is access to the software’s advanced history tracking. Key account events are tracked in the system and are searchable.

When the daily extract file from the core system is imported into ODP Manager, significant account status changes are tracked. Is the account newly overdrawn or now in good standing? Has an overdraft limit been added to or removed from the account? Has the consumer opted their account in to or out of ATM and everyday debit card transaction coverage according to Regulation E? Has the account been closed? These items are all tracked and retained in each individual account’s history.

When a user generates a collection, custom, or ad hoc letter, not only is the letter type, description, and date recorded, but also a PDF of the letter is saved and linked to the account history and the event history. All letters are stored within the application and can be regenerated at any time.

If a user needs to make further contributions to the account record, a comment or reminder can be created. Notes can be saved to the account as a comment. Reminders can be created for follow-up items with a specific due date. Both comments and reminders are accessible to all users and can include attachments.

Searching for events can be done for an individual account or across a range of dates. Individual account information is easily exported to PDF. Events occurring during a specified timeframe can be filtered and exported to Excel.

Please contact Strunk Support at support@strunkaccess.com with any questions or to find out more about ODP Manager’s advanced event history tracking.

Tracking Charge-Off Items and Recoveries

ODP Manager is updated daily, through the extract file import process, with the current information from the core processor; however, your users may benefit from some of the hosted software’s manual tracking features to monitor other data as well.

If your users need a better tool to manage the charge-off and recovery process after the deposit account has been closed, the Charge-Off Items and Recoveries feature included in ODP Manager may be helpful.

Once an account has charged off, you can create a charge-off item to track the charged off principal and fees. Notes can be added when the item is created or throughout the recovery process. Updates and changes are also logged. When recoveries are made, they should be entered in ODP Manager, reducing the overall balance tracked.

To monitor the overall status of charge-offs and recoveries, a summary screen displays basic charge-off information and status. By default, ODP Manager displays the Charge Off Items for the last year, but a different timeframe can be selected by specifying a start date and an end date. For reporting purposes, the charge-off item summary 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.

Inform Your Customers About Their Regulation E Opt-In Options

The Consent Form for Overdraft Services (A-9 form) provides your customer with the information they need to know about overdrafts and overdraft fees. In addition to serving as a disclosure of the appropriate information, it also facilitates a customer’s opt-in election by mail. Customers are also able to opt in over the phone, in person, or electronically.

When you include an account’s Reg E Opt-in election in the extract file imported into ODP Manager, ODP Manager can determine whether an account has already opted in or has not yet responded with a Reg E election. This means that your customers will receive the appropriate letter content based on their Regulation E Opt-in choice.

Strunk’s Welcome letter, Reinstatement letter, and Reg E Opt-In Followup letter templates make sure that your customers are aware of their options to opt in and that they know whether they already have the ATM and Everyday Debit Card transactions covered by their Overdraft Privilege limit.

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: by mail, online, in person, or by phone.

The ODP Manager software can identify which customers have not opted in and have an OD limit, in addition to other criteria. This allows you to communicate with these customers on an ongoing basis to send letters that explain the Reg E opt-in benefits and opt-in methods and that provide a consent form.

Strunk can also facilitate your customer’s online opt-in by creating 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.

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 for more details.

Simple and Efficient Management of the Fresh Start Loan Process using ODP Manager

Fresh Start Loans can help customers resolve their overdrawn account status with up to four payments and can allow them to keep their checking account open. Fresh Start Loans are also a collection tool that can help financial institutions recover and collect on overdrawn accounts that might have otherwise charged off and been closed. Leveraging the tools included in ODP Manager can make managing the Fresh Start Loan process easier and more efficient.

A repayment schedule can be entered for each account with an approved Fresh Start Loan. It will include payment reminders that display when the FSL payment is due to remind your users to check if the payment has been made as agreed. Once verified, FSL payments can also be tracked in ODP Manager.

Instead of needing to create agreements outside of Strunk’s ODP Manager, the Fresh Start Loan Agreement document can be generated directly from the repayment schedule. In addition to generating the agreement from the repayment schedule, users also have an option to generate the agreement as an Ad Hoc letter.

If customers under a repayment schedule do not pay their Fresh Start Loan payments as agreed, the default close letter can be generated and tracked in ODP Manager as well. If any other Fresh Start Loan letters are needed for accounts in a repayment status, an Ad Hoc letter template can be created. By entering the deposit account number, ODP Manager will pre-fill the account information. After the letter is generated, it will be tracked and retained in ODP Manager just like the other Collection and Custom letters.

ODP Manager includes a report that lists all accounts currently under a Fresh Start Loan status. If details are needed about current repayment schedules, a Repayment Schedule summary report can also be exported to PDF or Excel.

Please contact Strunk Support at support@strunkaccess.com with any questions or for more details.

Top 10 Overdraft Program Questions

Strunk offers overdraft privilege training to our clients to provide consistency on how the employees view the program and how the employees present the program to their consumers.  When providing training we will sometimes get questions on how to handle specific areas of the program. Here are the 10 most frequently asked questions during overdraft privilege training and the response to those questions.

1. Does a consumer have to opt in to have overdraft privilege on their account?

No, a consumer does not have to opt in to have the “standard overdraft practice” on their account.  The “standard overdraft practice” pay overdrafts for Checks, In-person withdrawals, ACH transactions, Pre-authorized automatic transfers, Automatic bill payments, Recurring debit card transactions, Internet banking transfers and telephone banking transactions.  A consumer only has to opt in to have their Everyday debit card transactions and their ATM transactions cover under the overdraft privilege program.

2. When does a financial institution have to take a consumer out of the overdraft privilege program for Excessive Use?

Never, financial institutions should never take a consumer out of the overdraft privilege program because they use it.  The key is not whether the account has had a lot of overdrafts, but rather, whether the account holder has made deposits sufficient to cover the overdrafts in a timely manner.

3. Does a consumer have to sign the Reg. E opt in form to have their debit card point of sale transactions and their ATM transactions covered?

No, a consumer only has to consent to have their debit card point of sale tractions and their ATM transactions covered under the overdraft privilege program.  The regulation provides for four methods to obtain an opt-in (consent): 1) by completing the form, 2) in person, 3) over the phone, and 4) electronically.  The financial institution should make the best possible use of all of these methods.

4. How can the financial institution differentiate between a recurring debit card transaction and a nonrecurring one?

Financial Institution must comply with the Reg. E rule if it adapts its system to identify debit card transactions as either onetime or recurring.  If it does so, the financial institution may rely on the transaction’s coding by merchants, other institutions, and other third parties as a one-time or preauthorized or recurring debit card transaction.

5. Do business accounts have to opt into Reg. E?

No, Reg. E is a consumer regulation.  Business accounts do not have to opt in to have their debit card or ATM transactions covered under the overdraft privilege program.

6. Does the Overdraft Privilege Joint guidance address the order in which charges are posted?

No, the Federal Register continues to assess whether additional regulatory action relating to overdraft services is needed, but nothing yet.

7. Do both parties have to opt into Reg. E on joint accounts?

If two or more consumers jointly hold an account, the financial institution must treat the affirmative consent of any of the joint consumers as affirmative consent for the account.  Similarly, the financial institution must treat a revocation of affirmative consent by any of the joint consumers as revocation of consent for that account.

8. Once a consumer pays back their Fresh Start Loan, can that consumer have their overdraft limit back?

Yes, once the consumers Fresh Start Loan is paid back in full and their account is in ‘good standings’, then their overdraft limit should be added back to their account.

 9. Can a consumer have more than 4 payments on their Fresh Start Loan?

No, a consumer can only have 4 monthly payments on their Fresh Start Loan. To qualify as incidental credit under Reg. B (for Reg. Z not to apply) and to avoid limitations under The Military Lending Act, the number of payments must be limited to 4 and no interest or fees are charged on the loan.

 10. Once an account is no longer suspended, when should that consumer get their overdraft limit back on their account?

Once a consumer account is in ‘good standing’ then that consumer should have an overdraft limit on their account.