In November 2010, the FDIC issued final guidance regarding overdraft protection programs that is the culmination of recent regulatory focus on the perceived poor practices by financial institutions in relation to automated overdraft programs. Even though your financial institution may not be regulated by the FDIC, it may be prudent to develop a program that will be compliant with the FDIC requirements in the event your primary regulator or the new Consumer Financial Protection Bureau adopts a similar plan.
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