Does Your Overdraft Payment Program Have Exclusion Creep?

For the past 27 years Strunk has been the leading provider of formal overdraft payment programs to financial institutions across the country. Many of these programs were put in place in the early to mid 2000’s, well before Regulation E changed the overdraft landscape in 2010.

Some financial institutions have let their programs die and others have put them on the back shelf as fee income derived from the service has gone down. Others continue to wonder what they can do to revitalize their 10-20 year old program.

So, what has happened? In virtually all financial institutions, the number of consumers participating in the formal overdraft program has dropped significantly. For one reason or another, the account holder has been taken out of the formal overdraft payment program. Strunk calls this “Exclusion Creep”. Virtually all of our 1,800 clients had 90%+ participation when the program was implemented but many institutions have 65-75% of their accounts in the program today.

Managing this is paramount to providing a good service to all of your customers and to maximizing fee income. Take a look at your consumer checking accounts and see if they have an overdraft limit assigned to the account. If not, re-qualify them and put them back in the program. Consumers want the service and managing the overdraft program like a line of business benefits everyone.

Does your financial institution have Exclusion Creep?

Managing Fee Waivers and Refunds

As the end of the year approaches, we have seen more and more clients loose potential additional fee income by waiving or refunding customer OD/NSF fees.  This is often lost income potential that is unknown to the institution. Generally most systems are set up to charge fees after the pay/return decisions have been made, so if the fees are waived the income never shows up on the general ledger as either income or the subsequent reversal of income.  Besides the reduction of fee income, waiving or refunding OD/NSF fees can also be a compliance issue.  Regulators have become increasingly sensitive to which accounts are not being held accountable for the fees that their activity dictates should be charged. For instance, if a high net worth individual is not charged overdraft (or other) fees that other accounts are routinely charged, this may be viewed as disparate treatment with all the ramifications that allegations of that nature involve.

The best solution to help alleviate both of these issues is to charge the fee “the night before”, or when the overdraft transactions are presented rather than waiting until the resolution of all items to post the fee. This helps accomplish the reduction in fee income simply because it requires more than a “click” to waive a fee, but rather a refund would need to be run for the reversal of the fee. This also allows for easier tracking of what is being given back to your account holders. With the gross fees as well as the individual refunds posting to the general ledger you can see at any given time how much the institution is giving away in fee income. From a compliance standpoint the institution is charging everyone on an equal basis – if an item overdraws the account then the account is charged – but the officer still has the discretion to refund the fee after the fact. This method is much more trackable and provides much more accountability for fee refunds.

Many of our clients cannot tell how much income they are giving back to customers each month. Part of the issue is addressed above regarding how to account for your fees and the associated waives, but the other issue is simply employees refunding fees back to customers when they ask for it, or sometimes even without them asking for it. In addition, very few institutions take the time to build reports, examine those reports, and hold their employees accountable on a consistent basis.

To assist in managing fee refunds, Strunk recommends that you implement the use of a “Refund Request Form” for employees to provide customers when they request a refund. This accomplishes multiple things. First, it allows the employee to avoid the face-to-face confrontation and having to make a snap decision. Second, it puts the emphasis for refunds back on the customer to show why it should be granted. This does not mean that we will no longer grant refunds, but we would like the customer to have to provide a valid reason why the institution should consider granting the request.

Take Advantage of ODP Opt-In Opportunities

How are you communicating with your account holders in your Overdraft Privilege Program? Are you able to not only advise account holders of the benefits of Overdraft Privilege but also remind them that they can authorize Overdraft Privilege service for ATM withdrawals and everyday debit card purchases? Strunk’s overdraft management application, ODP Manager, allows you to do just that!

You should consider sending both Welcome and Reinstatement letters to your account holders when overdraft limits have been assigned or when account holders requalify for Overdraft Privilege. When you send these letters to accounts that have not opted in for Regulation E, you should remind account holders that they have the option to authorize Overdraft Privilege for ATM and debit card transactions. ODP Manager can identify the accounts that have not opted in and generate a letter that includes the Consent Form for Overdraft Services and information about other ways to opt in. You can even set up a form in ODP Manager to allow your account holders to opt in online.

Additionally, ODP Manager allows you to send a letter periodically to account holders in your Overdraft Privilege program who have not opted in to or opted out of the ATM/everyday debit card Overdraft Privilege coverage. This is another opportunity to explain this additional feature to your account holders and to provide a consent form and additional opt-in methods.

Once you start taking advantage of these additional opportunities, the ODP Manager software can help you monitor your progress using daily reports and a dashboard that tracks progress over time.

Latest ODP Manager Enhancements

At Strunk, we are committed to providing best-in-class software solutions, and are constantly providing enhancements that we feel will best serve our clients. This month we are pleased to announce the addition of ODP Manager Dashboard within our industry-leading overdraft management application, ODP Manager.

ODP Manager clients will now be able to see their performance over time, as well as in comparison to our entire customer base, for five key indicators: Percent with Limit, Percent Opt In, Overdraft Fee, Consumer Overdraft Limit, and Business Overdraft Limit. The dashboard will graphically display the organization’s performance in purple as compared to the 25th, 50th and 75th percentile statistics for our entire client base. The Dashboard will also display the organization’s monthly trend for Percent with Limit and Percent Opt In.

Each quarter we will email clients a summary of their performance, along with tailored recommendations to address areas that may need attention. We believe the new ODP Dashboard will help clients more effectively monitor overdraft program key indicators and improve performance over time.

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.