Question:  Our bank is planning a big push on our "free" checking accounts with automatic overdraft protection.  Any compliance issues?

 

Answer:  Lots!  Be sure that your policies are in accordance with "best practices" published by the federal banking regulators.  Also, remember that Reg DD has been amended, effective July 1, 2006, to require special disclosures with advertising and new info on your periodic statement.  For example, if you promote overdraft protection, your periodic statements must show not only the NSF and OD fees by type and dollar but must include total dollar amount for each for the statement period and year to date.  Be sure that your policies, procedures, and data processing are in compliance.