International Law Office
Frequently Asked Questions and Answers on Overdraft Payment Programmes
May 6, 2011
The Federal Deposit Insurance Corporation (FDIC) recently issued frequently asked questions (FAQs) and answers in response to questions from FDIC-supervised institutions and third-party vendors about the FDIC’s Overdraft Payment Supervisory Guidance issued in November 2010. The FAQs provide further explanation of the FDIC’s supervisory expectations regarding overdraft payment programmes. The FAQs state that the FDIC expects institutions to have internally approved and “responsive” compliance and risk management action plans, policies and procedures for overdraft programmes in place by July 1, 2011.