Regulatory Updates Archive

Click on the links below to view past regulatory updates.

May 2023 Regulatory Update

New FDIC and OCC Guidance on Overdraft Programs

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November 2022 Regulatory Update

New CFPB Guidance on Illegal Junk Fees on Deposit Accounts

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November 2022 Reg Update – Supplemental Documents

The following documents referenced in the November Regulatory update are contained within this single PDF document for ease of downloading by Compliance Officers and Counsel for further reference.

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Fall 2022 Regulatory Update

Have You Reviewed Your Courtesy Overdraft Protection Program Lately?

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Regulatory Update - COVID-19, February 2021

Collection Practices During the COVID-19 Pandemic Health Emergency

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Fall 2020 Regulatory Update

Is COMMUNICATION Putting Your Financial Institution at Risk?

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Fall 2019 Regulatory Update

In this Issue:

 - Is Your Courtesy Overdraft Program Putting Your Financial Institution at Risk?
 - UDAP/Class Action Lawsuits
 - Regulation E
 - ECOA/Regulation B


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Overdraft Privilege Compliance Alert: One-time Debit Card and ATM Procedure Considerations

This article dscribes two procedural areas that may result in regulatory violations or consumer harm as it relates to one-time debit and ATM transaction affirmative opt-ins.

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Quarterly Newsletter: Division of Depositor & Consumer Protection

In this issue: 
- Automated Overdraft Program and One-Time Debit and ATM Opt-In Procedure Considerations
- FDIC's Money Smart for Adults Reboot
- Using American Community Survey (ACS) Data in Community Reinvestment Act (CRA) Examination
- Upcoming Chicago Region Community Affair Events

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Overdraft Privilege Compliance Alert: Debit Hold Considerations

Consumers are handling more and more of their transactions electronically and the payment and processing systems used by our industry are becoming increasingly complex. This combination of factors has led to a rise in accountholder confusion as to exactly when payments will be made from their accounts.
In the Winter 2014 issue of its publication, Supervisory Highlights, the CFPB provided a lengthy dissertation on balance definitions in the calculation of fees for debit card transactions and disclosures. In it, the CFPB has made it clear that certain debit holds may not be used in considering NSF charges unless properly and very clearly disclosed.

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CFPB's Key Findings from their Study of Overdraft Programs

On June 11, 2013 the CFPB released their white paper of initial data findings in their Study of Overdraft Programs. This Update summarizes those findings, lists areas the CFPB believes need further analysis, and discusses how the overdraft/NSF fee amount impacts revenue.

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Pinnacle's Response to CFPB's Request for Information on "Impact of Overdraft Programs on Consumers"

Pinnacle's responses reflect our more than 15 years of experience in providing fully disclosed, consumer focused overdraft programs to over 1,000 community banks and credit unions across the United States.

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Clarification of the FDIC Final Overdraft Program Guidance

This regulatory update provides explanation and implications of FDIC's clarification of FIL-81-2010 in response to questions and issues raised by member banks.

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FDIC Final Overdraft Payment Supervisory Guidance

Pinnacle's initial report on how to address FIL-81-2010. The guidance sets out the agencys expectations for how its supervised institutions should prudently oversee their overdraft payment programs.

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