Overdraft Compliance Risk Management Program

Recorded: November 6, 2025
Presented by: Ginger McCullough, Manager, Forvis Mazars, LLP.

With heightened oversight of overdraft programs, financial institution staff of all levels must understand what is required to maintain a compliant overdraft program and which practices may be challenged by regulators and attorneys.

This past few years has seen new guidance from the CFPB, FDIC and the OCC – and the potential for new rule making appears to be on the agenda. This heightened scrutiny essentially signals institutions – large and small alike – to get their overdraft programs in check.

Overdraft program compliance is not merely satisfaction with a single, clear-cut rule. Rather, compliance is riddled with multiple laws (e.g., Regulations E, DD and O), doctrines of fairness, supervisory guidance, UDAAP, and safety and soundness implications.

Overdraft compliance is so much more than being in compliance with clear-cut rules (e.g., Regulation E, DD, and O).  Rather, we must ensure doctrines of fairness, supervisory guidance, UDAAP, and safety and soundness implications.

Join this two and a half hour webinar as we highlight the key elements of overdraft service requirements, guidance and regulatory expectations, ensuring your overdraft compliance risk management program is up to par, best practices, examiner findings and more!  We will also highlight key trends triggering potential violations and litigation.

During the Overdraft Compliance Management Program webinar we will cover:

• Overdraft Compliance Management Program
• Regulatory Requirements
• Key Regulatory Guidance and Expectations
• Risk assessment considerations
• Emerging risks
• Best Practices
• Examiner Findings