Be proactive with your overdraft strategy

Amid all the talk about additional oversight of overdraft practices, the case for a fully disclosed, consumer-focused overdraft solution has never been more urgent.

In February, NCUA announced its supervisory priorities for 2024, signaling an intensified scrutiny of overdraft and nonsufficient fund fees. While the threshold for this focus had been on credit unions with more than $500 million in assets in 2023, NCUA Chairman Todd Harper announced that the threshold now includes all credit unions above $100 million in assets.

The stakes are higher than ever as examiners expand their evaluation to include reasonable and proportional overdraft fees, re-presentment, and authorize positive/settle negative (APSN). Moreover, Harper cautioned the industry that credit unions that rely too heavily on overdraft income will need to change their business model.

Between the CFPB’s proposed rule to “update regulatory exceptions for overdraft credit” and NCUA’s emphasis on eliminating problematic overdraft program practices, re-evaluating your overdraft strategy is a necessity. Remaining proactive to align market demands and regulatory expectations is paramount for sustainable growth.

A consumer-friendly overdraft service starts with carefully reviewing the program through the lens of your members. It’s about prioritizing transparent communication, including limits and fees.

Critics of overdraft services overlook the modern solutions and pro-consumer policies many credit unions adopt. Evolving best practices and clearly disclosed programs that are upfront about how the service works, including details about limits and fees, are key to putting your members first.

In fact, consumers have a need and are willing to pay for the service. A national survey conducted by Morning Consult found that:

• 88% of consumers found overdraft protection valuable.
• 77% of consumers who paid an overdraft fee in the past year were glad their payment was covered rather than being returned or declined.
• 63% percent of consumers think it’s reasonable to be charged a fee for an overdraft.

As industry leaders and policymakers deliberate on the future of overdrafts, acknowledging these realities becomes imperative.

Implementing a proactive overdraft strategy should align with offering a valuable, better service.

Consider these important areas when evaluating your overdraft strategy:

Reducing consumer costs. Demonstrating meaningful changes to your members is crucial. For instance, implementing a grace period and evaluating your fee are two ways to tackle fairness and reasonable fee structure issues.

If you have the technological capabilities, employing strategies like low balance alerts and early direct deposit can lower costs for your members. Understanding the impact of reactively making changes can be daunting. It’s paramount to ensure you have the right tools and expertise.

Mitigating institutional risk. You can pull a few levers to ensure the stability and resilience of your credit union. Reviewing disclosures, policies, and procedures for APSN transactions and re-presented items are significant areas that require time and resources.

Moreover, implementing robust risk management frameworks, conducting regular assessments of internal processes, and staying abreast of evolving regulatory requirements must be on your radar.

By proactively identifying and mitigating potential risks, you can safeguard your credit union’s operations and maintain trust among stakeholders. The challenge often is knowing where to look and having the right plan in place.

Minimizing examination risk. Maintaining accurate records, implementing better internal controls, and prioritizing transparency are key factors to reducing scrutiny. By proactively evaluating potential areas of concern and demonstrating a commitment to compliance, you can streamline the examination processes and reduce risks.

Additionally, having the right resources in place, including a compliance guarantee, eliminates concerns for many credit unions.

Don’t take a wait-and-see approach—show members you’re in their corner.

Redefining your credit union’s overdraft strategy will ensure you can deliver on your mission to promote financial health. These are among the best practices that can help you provide a responsible overdraft service that members can rely on.

When you put overdraft best practices into motion today, you’re planting the seeds of trust that can grow into stronger loyalty through all stages of members’ financial lives.

Visit advantage-fi.com to learn more about a pro-consumer review of your overdraft program.

JOHN COHRON is CEO at ADVANTAGE, a CSS alliance provider. This article is placed in partnership with ADVANTAGE and CSS, and does not represent the views of or an endorsement by America’s Credit Unions.