FDIC Study of Bank Overdraft Programs

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1 FDIC Study of Bnk Overdrft Progrms Federl Deposit Insurnce Corportion November 2008

2 Executive Summry In 2006, the Federl Deposit Insurnce Corportion (FDIC) initited two-prt study to gther empiricl dt on the types, chrcteristics, nd use of overdrft progrms operted by FDIC-supervised bnks. The study ws undertken in response to the recent rpid growth in the use of utomted overdrft progrms, defined s progrms in which the bnk honors customer s overdrft obligtions using stndrdized procedures to determine whether the nonsufficient fund (NSF) trnsction qulifies for overdrft coverge. Little empiricl dt hve been vilble on these progrms, their fetures, their mnging prctices, the fees imposed, nd consumer usge ptterns. Dt nd informtion for the FDIC s study were gthered through survey of smple of institutions representing 1,171 FDIC-supervised bnks, nd seprte dt request of customer ccount nd trnsction-level dt from smller set of 39 institutions. 1 The two-prt study ws designed to obtin the following types of informtion relted to overdrft progrms: chrcteristics, fetures, nd fees of overdrft progrms; trnsction-processing policies; mrketing nd disclosure prctices; internl controls nd monitoring prctices; the role of vendors nd third prties in overdrft progrm implementtion; nd NSF-relted fee income nd growth. The customer ccount nd trnsction-level dt collection ws designed to gther informtion on the provision of overdrft services on customer ccounts, the occurrence of NSF ctivity covered under utomted overdrft progrms, nd the chrcteristics of customer ccounts tht tend to incur the highest volume of overdrft fees. It ws lso designed to identify specific spects of overdrft progrm use tht my be pproprite for more rigorous quntittive inquiry. The FDIC believes tht objective informtion on these progrms will help policymkers mke betterinformed policy decisions nd will help the public better understnd the fetures nd costs relted to utomted overdrft progrms. The study results lso will help the bnking industry develop more effective overdrft progrms to better serve consumers. This report provides key study findings pertining to the growing provision of utomted overdrft progrms, enrollment prctices, credit limits nd fees, mrketing nd disclosure prctices, trnsction processing, nd NSF-relted revenues. Results from the ccount nd trnsction-level dt collection re lso included in this report bsed on the dt received from the 39 bnks. These ltter results suggest res tht my benefit from further study. Key findings from the survey of 462 FDIC-supervised bnks re s follows: 1. The mjority (86.0 percent) of bnks operted t lest one forml overdrft progrm either utomted, linked ccounts, or lines of credit (LOC). 2 Lrge bnks (defined s those with t lest $1 billion in ssets) tended to offer fuller menu of overdrft progrms. The shre of ll bnks offering utomted overdrft progrms ws 40.5 percent, but lrge bnks were lso significntly more likely to operte utomted overdrft progrms (76.9 percent), suggesting tht significnt shre of customer trnsction ccounts operted under utomted overdrft progrms. 1 The study popultion ws 1,171 FDIC-supervised institutions scheduled for on-site exmintions from My through December 2007 nd FDIC-supervised institutions with t lest $5 billion in ssets. The survey ws dministered to strtified, rndom smple of 462 institutions from the study popultion. The 39 bnks from which trnsction dt were received were nonrndom subset of the 462 bnks surveyed; therefore, the results re not generlizble beyond the 39-bnk smple. See Section II, Methodology, for more detiled discussion of the study methodology. 2 Automted overdrft progrms re usully computerized progrm by which the bnk honors customer s overdrft obligtions using stndrdized procedures or mtrix to determine whether the NSF occurrence qulifies for the overdrft coverge. Linked trnsfer ccounts (linked-ccounts) re defined s contrctul greement between bnk nd customer, linking the customer s trnsction ccount with other ccounts within the bnk, including svings nd credit crd ccounts. Overdrft lines of credit (LOCs) re contrctul greements between bnk nd customer stting tht the bnk will lend up to specified mount over defined period to cover overdrft items. FDIC Study of Bnk Overdrft Progrms n November 2008 November 2008 ii

3 Executive Summry 2. The number of FDIC-supervised institutions providing utomted progrms hs grown rpidly over the pst severl yers. Most bnks (69.4 percent) initited their utomted overdrft progrms fter Lrge bnks were more likely (55.4 percent) to hve hd n utomted overdrft progrm in plce in Most bnks (75.1 percent) utomticlly enrolled customers in utomted overdrft progrms, lthough customers were usully permitted to ffirmtively opt out of the progrm. Survey comments indicted tht in some cses, customers were not given the choice to opt in or out of the utomted progrm. 4. By contrst, lmost ll bnks (94.7 percent) treted linked-ccount progrms s opt-in progrms, requiring tht customers ffirmtively request to hve ccounts linked. In ddition, customers hve to pply nd qulify for n overdrft LOC progrm, so these progrms typiclly operte on n opt-in bsis. 5. Most bnks (73.0 percent) estblished credit limits for utomted overdrft customers in written policies, consistent with the bnk s lending progrm. Automted overdrft credit limits stipulted in these policies rnged from $85 to $10,000, nd the medin credit limit ws $ Automted overdrft usge fees ssessed by bnks rnged from $10 to $38, nd the medin fee ssessed ws $27. About one-fourth of the surveyed bnks (24.6 percent) lso ssessed dditionl fees on ccounts tht remined in negtive blnce sttus in the form of flt fees or interest chrged on percentge bsis. 7. Fees ssessed for linked-ccount nd overdrft LOC progrms were typiclly lower thn for utomted overdrft progrms. Almost hlf of the bnks with linked-ccount progrms (48.9 percent) reported chrging no explicit fees for the service. The most common fee ssocited with linkedccount progrms ws trnsfer fee; where chrged, the medin trnsfer fee ws $5. The primry cost ssocited with overdrft LOC progrms ws the interest chrged on funds dvnced, usully ccruing t n nnul percentge rte (APR) of round 18 percent. 8. The mjority (81.0 percent) of bnks operting utomted progrms llowed overdrfts to tke plce t utomted teller mchines (ATMs) nd point-of-sle (POS)/debit trnsctions. However, most bnks whose utomted overdrft progrms covered ATM nd POS/debit trnsctions informed customers of n NSF only fter the trnsction hd been completed (88.8 percent of bnks for POS/debit trnsctions nd 70.7 percent of bnks for ATM trnsctions). A minority of bnks (7.9 percent for POS/debit nd 23.5 percent for ATMs) did inform consumers tht funds were insufficient before trnsctions were completed t these loctions, offering the customers n opportunity to cncel the NSF trnsction nd void fee. 9. A significnt shre of bnks (24.7 percent of ll surveyed bnks nd 53.7 percent of lrge bnks) btched processed overdrft trnsctions by size, from lrgest to smllest, which cn increse the number of overdrfts. 10. More thn hlf of bnks with utomted overdrft progrms (54.2 percent) reported tht they relied on third-prty vendor to implement or mnge the progrm. Smll bnks (those with less thn $250 million in ssets) were more likely to rely on vendors nd third prties for utomted overdrft progrm implementtion nd mngement. Most bnks using vendors to mnge their utomted overdrft progrms (70.6 percent) lso reported tht they pid third-prty vendors percentge of the fees generted by the progrm, typiclly 10 to 20 percent of dditionl fees generted. 11. The bnks erned n estimted $1.97 billion in NSF-relted fees in 2006, representing 74 percent of the $2.66 billion in service chrges on deposit ccounts reported by these bnks in their Reports of Conditions nd Income (Cll Reports). 3 Totl NSF-relted fee income ccounted for roughly 3 Bnks were sked to report nnul NSF-relted fee income ssocited with the processing of ll NSF trnsctions. Fee income dt cited re estimtes for study popultion bnks only nd do not represent estimtes for other segments of the bnking industry. FDIC Study of Bnk Overdrft Progrms n November 2008 iii

4 Executive Summry 6 percent of the totl net operting revenues erned by the bnks. Bnks operting utomted overdrft progrms erned $1.77 billion in NSF fees in 2006, ccounting for 90 percent of totl NSFrelted fee income erned by the entire study popultion. 12. Bnks tht operted utomted overdrft progrms hd higher NSF-relted fee income (mesured s shre of operting revenues) compred with other bnks. In ddition, bnks whose utomted progrm covered ATM nd/or POS/debit trnsctions nd bnks tht btch processed trnsctions lrgest-to-smllest reported higher fee income thn those tht did not hve these fetures. 13. Consumer complints bout utomted overdrft progrms were received by 12.5 percent of bnks tht operted these progrms, compred with consumer complints from less thn 1.0 percent of bnks offering linked-ccount progrms nd 1.5 percent of bnks offering overdrft LOC progrms. Complints bout utomted overdrft progrms were more common for lrge institutions thn for smll institutions (21.7 percent versus 10.6 percent). 14. Automted overdrft progrms operted by bnks were chrcterized s either promoted or nonpromoted. 4 The survey results reveled importnt differences in bnk mrketing nd disclosure prctices between utomted nd nonutomted overdrft progrms. However, in most cses survey disclosure results regrding utomted overdrft progrms pplied only to promoted progrms. Although bnks tht operted nonpromoted utomted overdrft progrms ccounted for minority (8.5 percent) of bnks, these bnks were typiclly lrge nd ccounted for more thn hlf (51.7 percent) of the trnsction ccount dollrs held by ll bnks. Results from the nlysis of micro-level dt from 39 bnks with ggregte ssets totling $332 billion nd 6.5 million customer ccounts re s follows: 5 1. Micro-dt bnks reported 22.6 million NSF trnsctions incurred by consumer ccounts during the 12-month period of nlysis. Almost ll (22.5 million) of the NSF trnsctions nlyzed were reported by bnks tht operted utomted overdrft progrms. 2. Although lmost 75 percent of consumer ccounts hd no NSF trnsctions during the 12-month period exmined, lmost 12 percent of consumer ccounts hd 1 to 4 NSF trnsctions, 5.0 percent hd 5 to 9 NSF trnsctions, 4.0 percent hd 10 to 19 NSF trnsctions, nd 4.9 percent hd 20 or more NSF trnsctions. Almost 9 percent of consumer ccounts of bnks reporting dt hd t lest 10 NSF trnsctions during the 12-month period of nlysis Customers with 5 or more NSF trnsctions ccrued 93.4 percent of the totl NSF fees reported for the 12-month period. Customers with 10 or more NSF trnsctions ccrued 84 percent of the reported fees. Customer ccounts with 20 or more NSF trnsctions ccrued over 68 percent of the reported fees. 4. Customer ccounts with 1 to 4 NSF trnsctions were chrged $64 per yer in NSF fees on verge. Customer ccounts with 5 to 9 NSF trnsctions were chrged $215 per yer in NFS fees on verge. Customer ccounts with 10 to 19 NSF trnsctions were chrged $451 per yer in NFS fees on verge. Customer ccounts with 20 or more NSF trnsctions were chrged $1,610 per yer in NSF fees on verge. 4 Promoted utomted overdrft progrms re those in which the customers re informed of the existence of the overdrft progrm. Nonpromoted utomted overdrft progrms re those in which customers re not informed of the existence of the overdrft progrm. 5 Bnk ssets reported s of December For this study, NSF trnsction dt include NSFs covered by n utomted overdrft progrm nd returned or unpid, s well s NSFs processed on n d hoc bsis, lthough nerly ll NSFs were reported by bnks tht operted utomted overdrft progrms. Dt on NSF trnsctions processed under linked-ccounts or LOC progrms were not collected. FDIC Study of Bnk Overdrft Progrms n November 2008 iv

5 Executive Summry 5. Accounts held by customers in low-income res (in some res, medin nnul income of less thn $30,000) were more likely thn ccounts in higher-income res to incur overdrft chrges. 7 More thn 38 percent of low-income ccounts hd t lest one NSF trnsction, compred with 22 percent of upper-income ccounts. 6. Recurrent overdrfts were lso more likely the lower the income group. Among low-income customers, 16.7 percent of ccounts hd 1 to 4 NSF trnsctions, nd 7.5 percent hd 20 or more NSF trnsctions. By comprison, 13.9 percent of ccounts held by moderte-income consumers hd 1 to 4 NSF trnsctions, nd 6.4 percent hd 20 or more NSF trnsctions. Consumers in upper-income res hd 1 to 4 NSF trnsctions in 10.5 percent of ccounts nd 20 or more NSF trnsctions in 3.8 percent of ccounts. 7. Almost hlf (48.8 percent) of ll reported NSF trnsctions took plce t POS/debit (41.0 percent) nd ATM (7.8 percent) terminls. Checks ccounted for 30.2 percent of the reported NSF trnsctions. 8. The medin dollr mount of ll 22.5 million trnsctions processed by the micro-dt bnks with utomted overdrft progrms ws $36. POS/debit NSF trnsctions were not only the most frequent, but lso the smllest, with medin dollr vlue of $20. The medin trnsction size of n ATM withdrwl nd check tht resulted in n NSF trnsction were $60 nd $66, respectively. 9. Assuming $27 overdrft fee (the survey medin), customer repying $20 POS/debit overdrft in two weeks would incur n APR of 3,520 percent; customer repying $60 ATM overdrft in two weeks would incur n APR of 1,173 percent; nd customer repying $66 check overdrft in two weeks would incur n APR of 1,067 percent. More rpid repyment of the overdrft mount results in higher APRs, nd slower repyment results in lower APRs Accounts held by young dults (ges 18 to 25) were the most likely mong ll ge groups to hve utomted overdrft NSF ctivity. Among young dult ccounts, 46.4 percent incurred NSF ctivity, compred with 12.2 percent of ccounts held by seniors (over ge 62) nd 31.9 percent of ccounts held by other dults. Nerly 15 percent of ccounts held by young dults recorded more thn ten NSF trnsctions during the yer, compred with 12.1 percent of dult ccounts nd 3.0 percent of senior ccounts. Most NSF trnsctions mde by young dult ccounts (61.7 percent) originted t POS/debit terminl. 7 Actul medin income limits for ech income level designtion vry by metropolitn sttisticl re. The income limit provided is benchmrk clculted bsed on the 2006 medin fmily income for the United Sttes. (Source: U.S. Census Bureu, 2006 Americn Community Survey.) 8 These exmples ssume tht the credit extended s result of the overdrft occurrence equled the totl trnsction, tht the consumer repid the credit extended in two weeks, nd tht no dditionl fees re imposed on the consumer s result of the NSF. The APRs were clculted s follows: ((Fee Chrged/Amount Finnced)*365)/Term (14 dys). FDIC Study of Bnk Overdrft Progrms n November 2008 v

6 FDIC Study of Bnk Overdrft Progrms Tble of Contents Executive Summry ii I. Introduction 1 II. Methodology 1 II.1. Overdrft Survey Methodology 2 II.2. Micro-Level Dt Methodology 3 Prt One Overdrft Survey 5 III. Overview of Overdrft Progrms 5 III.1. Progrms Operted 5 III.2. Account nd Trnsction Coverge 8 III.3. Trnsction Processing Prctices 11 III.4. Summry 12 IV. Overdrft Fees nd Credit Limits 13 IV.1. Automtic Overdrft Progrm Fees nd Coverge Limits 13 IV.2. Fees on Linked-Account Progrms 19 IV.3. Fees, APRs, nd Credit Limits on Overdrft LOCs 21 IV.4. Summry 24 V. Customer Enrollment, Mrketing, nd Disclosure Prctices 25 V.1. Offering Overdrft Progrms to New Customers 25 V.2. Enrollment in Overdrft Progrms 27 V.3. Providing Comprtive nd Eductionl Informtion to Consumers 27 V.4. Product Line Informtion Provided to Consumers 30 V.5. ATM nd POS/Debit Blnce Disclosures 38 V.6. Summry 42 VI. Internl Controls nd Monitoring Systems 43 VI.1. Written Policies 43 VI.2. Complince Review Prior to the Implementtion of the Overdrft Progrm 45 VI.3. Methods for Monitoring nd Evluting Overdrft Progrms 46 VI.4. Ongoing Customer-Level Monitoring of Overdrft Progrms 48 VI.5. Summry 50 VII. The Role of Vendors nd Third Prties in Overdrft Prctices 50 VII.1. Vendor Usge 51 VII.2. Vendor Compenstion Structure 53 VII.3. Summry 55

7 Tble of Contents VIII. Growth nd Profitbility of Overdrft Progrms: The Importnce of NSF-Relted Fee Income for Bnk Ernings 55 VIII.1. Income Shre Results 56 VIII.2. Fee Income s Shres of Deposits 59 VIII.3. Chrged-Off nd Restructured Accounts 62 VIII.4. Net Fee-Income Rtios 65 VIII.5. Trends in NSF-Relted Fee Income 65 VIII.6. NSF-Relted Fee Income nd the Adoption of Automted Overdrft Progrms 67 VIII.7. Summry 68 Prt Two Micro-Level Dt 70 IX. Micro-Level Dt: Consumer Overdrft Usge 70 IX.1. Overview of Overdrft Progrms Operted nd Account Coverge of Micro-Dt Bnks 70 IX.2. Chrcteristics of Automted Overdrft Progrms Operted by Micro-Dt Bnks 72 IX.3. Ptterns of NSF Activity nd Fees for Micro-Dt Bnks with Automted Overdrft Progrms 76 IX.4. Summry 81 FDIC Study Group on Bnk Overdrft Progrms 83 Appendix A FDIC Overdrft Protection Survey I A-1 Appendix B FDIC Overdrft Protection Survey II B-1 List of Tbles nd Figures Tble II-1 Smple Summry 3 Tble III-1 Forml Overdrft Progrms Operted 5 Tble III-2 Menu of Overdrft Progrms Operted 6 Tble III-3 Promoted nd Nonpromoted Automted Progrms 7 Figure III-1 Distribution of Study Popultion, by Automted Overdrft Progrms Operted 7 Figure III-2 Distribution of Trnsction Account Dollrs Held in Study Popultion by Automted Progrms Operted 7 Tble III-4 Bnks with Forml Overdrft Progrm Implemented by Tble III-5 Accounts Covered by Forml Overdrft Progrms 9 Tble III-6 Account Coverge by Multiple Overdrft Progrms 9 Tble III-7 Order Overdrft Progrms Invoked 10 Tble III-8 Trnsctions Covered by Forml Overdrft Progrms 10 Tble III-9 Btch-Processing Methods 11 Tble III-10 Trnsctions Pid First 12 Tble IV-1 The Incidence of Fees Chrged by Automted Overdrft Progrms 14 Tble IV-2 Usge Fees for Automted Overdrft Progrms 14 Tble IV-3 Per-Item Fees Chrged by Automted Overdrft Progrms 15 Tble IV-4 Initition nd Mintennce Fees for Automted Overdrft Progrms 17 Tble IV-5 Fetures of Usge-Relted Fees for Automted Overdrft Progrms 17 FDIC Study of Bnk Overdrft Progrms n November 2008 vii

8 Tble of Contents Tble IV-6 Credit Limits of Automted Overdrft Progrms 18 Tble IV-7 NSF Fees Chrged by Study Popultion Bnks 18 Tble IV-8 The Incidence of Fees Chrged by Linked-Account Overdrft Progrms 19 Tble IV-9 Fees for Linked-Account Overdrft Progrms 20 Tble IV-10 Fetures of Linked-Account Trnsfer Fees 21 Tble IV-11 The Incidence of Noninterest Fees Chrged by Overdrft LOC Progrms 22 Tble IV-12 Noninterest Fees Chrged by Overdrft LOC Progrms 23 Tble IV-13 APRs for Overdrft LOC Progrms 23 Tble IV-14 Credit Limits of Overdrft LOC Progrms 24 Tble V-1 How Institutions with Two or More Overdrft Progrms Determine Offerings to New Customers 26 Tble V-2 Customer Qulifiction Rules for Automted Overdrft Progrms 26 Tble V-3 Whether Opt-In/Opt-Out 27 Tble V-4 Informtion Provided to Consumers to Compre Overdrft Progrms t Institutions with Two or More Overdrft Progrms 28 Tble V-5 Eductionl Informtion Provided to Consumers by Institutions with Forml Overdrft Progrms 29 Tble V-6 Timing of Informtion Provided to Consumers for Promoted Automted Progrms 31 Tble V-7 Timing of Informtion Provided to Consumers for Linked-Account nd Overdrft LOC Progrms 32 Tble V-8 Mens of Informing Consumers bout Promoted Automted Progrms 33 Tble V-9 Mens of Informing Consumers bout Linked-Account nd Overdrft LOC Progrms 34 Tble V-10 Content of Informtion Provided to Consumers bout Promoted Automted Progrms 35 Tble V-11 Content of Informtion Provided to Consumers bout Linked-Account nd Overdrft LOC Progrms 36 Tble V-12 Advertising for Promoted Automted Progrms 37 Tble V-13 Advertising for Linked-Account nd Overdrft LOC Progrms 38 Tble V-14 Blnces Shown t ATMs for Promoted Automted Progrms 39 Tble V-15 Blnces Shown t ATMs for Overdrft LOC Progrms 40 Tble V-16 Customer Notifiction of ATM nd/or POS/Debit NSF for Automted Overdrft Progrms 41 Tble V-17 Customer Notifiction of ATM nd/or POS/Debit NSF for Overdrft LOC Progrms 42 Tble VI-1 Overdrft Progrm Policies for Automted Overdrft Progrms 44 Tble VI-2 Complince Review Policies for Automted Overdrft Progrms 46 Tble VI-3 Evlution of Automted Overdrft Progrms 47 Tble VI-4 Mintennce of Consumer Informtion nd Monitoring of Excessive Use of Overdrft Progrms 48 Tble VI-5 Other Monitoring of Automted Overdrft Progrms 49 Tble VI-6 Complints bout Automted Overdrft Progrms 49 Tble VII-1 Institutions Reltionships with Vendors for Automted Overdrft Progrms 51 Tble VII-2 Length of Vendor Reltionships for Automted Overdrft Progrms 52 Tble VII-3 Type of Vendor Progrm Used for Automted Overdrft Progrms 53 Tble VII-4 Vendor Compenstion for Automted Overdrft Progrms 54 Tble VIII-1 NSF-Relted Fee Income s Shre of Broder Income Mesures 57 Tble VIII-2 NSF-Relted Fee Income s Shre of Broder Income Mesures by Qurtiles 58 FDIC Study of Bnk Overdrft Progrms n November 2008 viii

9 Tble of Contents Tble VIII-3 NSF-Relted Fee Income Rtios to Deposits Outstnding 60 Tble VIII-4 NSF-Relted Fee Income Rtios to Deposits Outstnding by Qurtiles 61 Tble VIII-5 Chrged-Off nd Restructured Deposit Accounts in Tble VIII-6 Net NSF-Relted Fee Income Rtios 64 Tble VIII-7 Trends in NSF-Relted Fee Income: Tble VIII-8 Trends in NSF-Relted Fee Income Rtios by Qurtiles 67 Figure VIII-1 Chnges in the Rtion of NSF-Relted Fee Income to Net Operting Revenue 68 Figure VIII-2 Chnges in the Rtio of NSF-Relted Fee Income to Averge Trnsction Deposits 68 Tble IX-1 Consumer Trnsction Accounts nd Deposit Dollrs Held in Micro-Dt Bnks by Overdrft Progrm Type Offered 71 Tble IX-2 Overdrft Protection Progrms Offered by Micro-Dt Bnks 71 Tble IX-3 Overdrft Progrm Coverge for Consumer Trnsction Accounts for All Micro-Dt Bnks 72 Tble IX-4 Type of Accounts by Neighborhood Income for Micro-Dt Bnks with Automted Overdrft Progrms 72 Tble IX-5 Opt-In/Opt-Out Policies of Micro-Dt Bnks with Automted Overdrft Progrms 73 Tble IX-6 Trnsctions Covered by Micro-Dt Bnks with Automted Overdrft Progrms 73 Tbe IX-7 Trnsction Btch-Processing Method for Micro-Dt Bnks with Automted Overdrft Progrms 74 Tble IX-8 Medin Fmily Income Thresholds by Census Trct Income Brcket 74 Tble IX-9 Tble IX-10 Tble IX-11 Tble IX-12 Tble IX-13 Tble IX-14 Tble IX-15 Tble IX-16 Tble IX-17 Customer Accounts by Income Group for Micro-Dt Bnks with Automted Overdrft Progrms 75 Account Blnce by Averge Dollr Amount Held nd Income Group for Micro-Dt Bnks with Automted Overdrft Progrms 75 Customer Accounts by Number of NSF Trnsctions per Yer nd Income Group for Micro-Dt Bnks with Automted Overdrft Progrms 76 NSF Fees Chrged by Income Group nd by Number of NSF Trnsctions per Yer for Micro-Dt Bnks with Automted Overdrft Progrms 77 Annul Dollr Amount of NSF Fees Chrged per Consumer Account for Micro-Dt Bnks with Automted Overdrft Progrms 77 Customer Accounts nd NSF Fees by Number of NSF Trnsctions per Yer for Bnks with No Automted Overdrft Progrm 77 NSF Trnsctions by Income Group nd Trnsction Type for Micro-Dt Bnks with Automted Overdrft Progrms 78 NSF Trnsctions by Income Group nd Trnsction Type for Micro-Dt Bnks with Nonutomted Overdrft Progrms 78 Medin NSF Trnsction Amount by Income Group nd Type of Trnsction for Micro-Dt Bnks with Automted Overdrft Progrms 79 Tble IX-18 Customer Accounts by Age Group for Micro-Dt Bnks with Automted Overdrft Progrms 80 Tble IX-19 Tble IX-20 Tble IX-21 Customer Accounts by Number of NSF Trnsctions in Yer per Age Group for Micro-Dt Bnks with Automted Overdrft Progrms 80 NSF Trnsctions by Age Group nd Trnsction Type for Micro-Dt Bnks with Automted Overdrft Progrms 80 Medin NSF Trnsction Amount by Age Group nd Type of Trnsction for Micro-Dt Bnks with Automted Overdrft Progrms 81 FDIC Study of Bnk Overdrft Progrms n November 2008 ix

10 I. Introduction This report detils the methodology nd findings of the Federl Deposit Insurnce Corportion s (FDIC) study of overdrft progrms operted by segment of finncil institutions. Over the pst few yers, the use of utomted overdrft progrms hs risen significntly, but little empiricl dt hve been vilble on these progrms, their fetures, their mngement, the fees imposed, nd consumer usge ptterns. The FDIC initited this two-prt study in 2006 to gther empiricl dt on the types, chrcteristics, nd use of overdrft progrms operted by FDIC-supervised bnks. The study ws undertken s prt of the gency s mission to protect consumers, which it crries out by monitoring complince with consumer protection lws nd regultions for the bnks tht it supervises, educting the public bout finncil mtters, nd implementing progrms tht help promote economic inclusion. The study lso reflects the FDIC s responsibility to monitor the sfety nd soundness of bnks, including the prolifertion of new or different types of credit. Dt nd informtion for this study were gthered through survey of 462 rndomly selected FDICsupervised institutions nd collection of customer nd trnsction-level dt from smller set of the surveyed FDIC-supervised institutions. The survey portion of the study ws designed to obtin vrious types of informtion relted to overdrft progrms, including fetures nd chrcteristics, fees, processing policies nd prctices, mrketing prctices, disclosure, growth nd revenue trends, nd the role of vendors or other third prties in overdrft progrm implementtion. The survey instrument cn be found in Appendix A of this document. The micro-dt collection portion ws designed to gther informtion on the types of ccounts nd trnsctions tht tend to generte the highest volume of overdrft fees nd the chrcteristics of consumers who use utomted overdrft progrms. The dt collection instrument cn be found in Appendix B of this document. The FDIC believes tht objective informtion on these progrms will help policymkers mke betterinformed policy decisions nd will help the public better understnd the fetures nd costs relted to utomted overdrft progrms. The study results lso will help the bnking industry develop more effective overdrft progrms to better serve consumers. The structure of this report is bsed on the survey nd micro-dt request, nd the report is in two prts. The first prt is bsed on the survey instrument nd contins n overview of the overdrft progrms; overdrft fees nd credit limits; customer enrollment, mrketing, nd disclosure prctices; internl controls nd monitoring systems; the role of vendors nd third prties in overdrft prctices; nd the growth nd profitbility of overdrft progrms. The second prt of this report is bsed on the micro-level dt gthered regrding consumer overdrft usge. 1 II. Methodology The results presented in this report rely on informtion gthered from U.S. bnks through (1) survey, nd (2) collection of micro-level customer nd trnsction-level dt (micro-dt). The study popultion included FDIC-supervised bnks tht were visited by exminers, most s prt of scheduled on-site exmintions, from My through December The surveyed institutions represent 1,171 bnks locted throughout the United Sttes, which re defined lter in Section II.1. 1 The ctul survey nd micro-dt requests cn be found in Appendices A nd B, respectively. 2 As of the universe selection dte, September 30, 2006, there were 5,237 FDIC-supervised bnks, number tht included both stte-chrtered, nonmember commercil bnks nd stte-chrtered svings bnks. FDIC November Study 2008 of Bnk Overdrft Progrms n November

11 II. Methodology II.1. Overdrft Survey Methodology The overdrft survey involved the collection of dt nd informtion on FDIC-supervised overdrft progrms nd prctices through completion of survey dministered to strtified rndom smple of FDIC-supervised institutions. The survey, ttched s Appendix A, consisted of pproximtely 90 questions bout overdrft progrms nd prctices. The first section of the survey instrument collected ggregte nd generl informtion on ech institution s scope of overdrft services, income erned from overdrft progrms, generl overdrft processing prctices, nd generl disclosure prctices. The second section of the survey instrument collected detiled, progrm-specific dt relted to policies, monitoring prctices, customer disclosure, fees, ccount coverge, nd use of third-prty vendors for the following types of overdrft progrms or prctices most commonly used by bnks: 1) Automted overdrft progrms: usully computerized progrm by which the bnk honors customer s overdrft obligtions using stndrdized procedures or mtrix to determine whether the nonsufficient fund (NSF) occurrence qulifies for the overdrft coverge. Promoted utomted overdrft progrms re those in which the customers re informed of the existence of the overdrft progrm. Nonpromoted utomted overdrft progrms re those in which customers re not informed of the existence of the overdrft progrm. 2) Linked trnsfer ccounts (linked-ccounts): defined s contrctul greement between bnk nd customer, linking the customer s trnsction ccount with other ccounts within the bnk, including svings nd credit crd ccounts. In the event of n overdrft, the bnk fulfills the customer s obligtions by trnsferring funds from the customer s other ccounts linked to the customer s trnsction ccount. 3) Overdrft lines of credit (LOCs): contrctul greement between bnk nd customer stting tht the bnk will lend up to specified mount over defined period to cover overdrft items. These progrms exclude LOC progrms tht do not specificlly cover overdrft items (e.g., home equity LOCs). The bnk initilly extends the overdrft LOC fter reviewing customer s qulifictions using stndrd underwriting criteri; the LOC is considered lon nd requires stndrd Truth in Lending Act (Regultion Z) disclosures. After the initil decision to grnt the LOC, the lender generlly does not mke decision whether to cover individul overdrfts tht fll under the credit limit. 4) Ad hoc overdrft: n informl progrm to cover customers overdrfts. The study lso sked institutions bout informl overdrft prctices, if ny, outside the prmeters of the three forml progrms described bove. FDIC exminers dministered the questionnire during scheduled on-site visits to reduce reporting burden, increse the ccurcy of survey responses, nd increse survey response rtes. Extr steps were tken to ensure tht the degree of ccurcy for the on-site questionnire ws high, including development of stndrd computer progrms to collect the dt, specilized trining of exminers to conduct the on-site surveys, nd regulr discussions to nswer ny questions during the survey. The study popultion included (1) 1,135 institutions with less thn $5 billion in ssets tht were scheduled for on-site visits by FDIC exminers between My nd December 2007, nd (2) 36 FDICsupervised institutions with more thn $5 billion in ssets regrdless of whether n exmintion ws scheduled. Nonretil bnks, such s credit crd bnks nd industril lon compnies, were excluded from the underlying study popultion since the focus of the survey ws on retil-oriented overdrft progrms nd policies. FDIC Study of Bnk Overdrft Progrms n November

12 II. Methodology The survey ws dministered to strtified rndom smple of 462 finncil institutions from mong the study popultion of 1,171 FDIC-supervised institutions. 3 The strt were defined by three sset sizes (institutions with less thn $250 million in ssets; ssets between $250 million nd $1 billion; nd ssets greter thn $1 billion). Institutions in the lrger strt were smpled t higher rtes to ensure tht substntil proportion of deposit ccounts held in the study popultion were included. In prticulr, ll of the 108 institutions in the popultion with more thn $1 billion in ssets were included in the smple. Also, the institutions in the $250 million to $1 billion strtum were smpled t more thn twice the rte s those in the less thn $250 million strtum. (See tble below for exct smple sizes nd smple percentges.) To derive unbised estimtes for the study popultion, the differentil smpling rtes pplied cross the size strt were tken into ccount. As mentioned bove, the survey smple included 36 FDIC-supervised institutions with more thn $5 billion in ssets nd 72 institutions with ssets between $1 billion nd $5 billion scheduled to be exmined during the dt collection window. In ddition, the survey smple included 354 bnks rndomly selected from mong 1,063 institutions with less thn $1 billion in ssets. Tble II-1 below summrizes the smple nd study popultion nd counts by strt; it lso includes strtum smpling percentges. Tble II-1 Smple Summry Asset Size Strtum Study Popultion Totl Smple Percent Smpled $250 million $250 million to $1 billion $1 billion to $5 billion Greter thn $5 billion Totl 1, Becuse the smple of institutions ws selected from the 1,171 institutions in the study popultion, it is not sttisticl smple of ll 5,237 FDIC-supervised institutions. Therefore, unbised estimtes of survey chrcteristics cn be mde only for the 1,171 institutions in the study popultion. It is not possible to drw sttisticlly defensible inferences from the smple dt bout bnks outside of the underlying study popultion, including bnks supervised by other gencies (such s ntionl bnks, nd stte-chrtered Federl Reserve member bnks or thrifts). II.2. Micro-Level Dt Methodology The micro-dt request gthered ccount-level informtion nd overdrft coverge for ll customer ccounts. The micro-dt lso collected dt on ll NSF trnsctions processed under n institution s utomted overdrft progrm or under d hoc overdrft coverge. (This includes items returned s unpid.) The micro-dt request cn be found in Appendix B. The micro-dt were collected from nonrndom subsmple of the bnks surveyed. As this portion of the study involved nonrndom smple, it is not possible to drw sttisticl inferences to ny broder popultion of bnks using these dt. Nevertheless, the FDIC believes tht these dt provide vluble informtion bout consumer usge nd fee genertion relted to utomted overdrft progrms. 3 In ddition, the FDIC collected survey dt from seven Puerto Ricn bnks. However, nlysis of survey results reveled tht the surveyed Puerto Ricn bnks hd meningful differences in their use of overdrft progrms compred with the reminder of the survey popultion nd, in fct, tended not to offer such progrms. Consequently, Puerto Ricn bnks were not included in this study popultion. FDIC Study of Bnk Overdrft Progrms n November

13 II. Methodology Approximtely 100 bnks of different sizes, loctions, nd overdrft progrms were identified s potentil nonrndom micro-dt collection cndidtes. Lrge bnks nd bnks whose informtion could more esily be gthered through greements with their existing softwre providers were given priority in prticiption in the micro-level dt collection. To fcilitte the dt-gthering process for smller bnks, the FDIC relied on softwre developed by vendors tht serviced finncil institutions in the survey smple. The FDIC lso used stndrd computer progrms to ensure tht dt gthering ws ccurte nd consistent cross the study popultion. In ddition, the FDIC conducted periodic telephone conferences with both FDIC field stff nd bnkers to help disseminte informtion on how to gther nd submit the requested informtion. The micro-dt used for this study include dt for 39 of the 100 bnks initilly identified s potentil cndidtes, covering pproximtely 6.5 million consumer ccounts nd 22.6 million NSF trnsctions. Twelve months of dt between Jnury 2005 nd September 2008 were collected from ech of these bnks; the dt included informtion bout ccount types, ccount ctegory, nd customer use of utomted overdrft progrms. FDIC Study of Bnk Overdrft Progrms n November

14 Prt One Overdrft Survey III. Overview of Overdrft Progrms This section provides n overview of survey findings relted to overdrft progrms nd the timefrme of progrm doption, the ccounts nd trnsctions covered by these progrms, nd the methods by which institutions processed trnsctions. The survey ws primrily focused on utomted overdrft progrms; however, to provide bsis of comprison, dt were lso collected for linked-ccount progrms, overdrft LOC progrms, nd d hoc prctices. All tbles strtify the study popultion bnks by sset size, where smll bnks re defined s those with less thn $250 million in ssets, medium bnks s those with $250 million to $1 billion in ssets, nd lrge bnks s those with more thn $1 billion in ssets, s of December III.1. Progrms Operted Study popultion bnks were sked to define ll overdrft progrms in opertion specificlly, whether they hd promoted or nonpromoted utomted progrm, linked-ccount progrm, or n overdrft LOC progrm nd to describe ny overdrft coverge services outside of these three forml progrms. The survey lso sked the yer nd month in which bnks dopted specific overdrft progrm. The first yer in which bnk operted progrm for six months or more ws considered the strt yer of the progrm. Most study popultion bnks (85.9 percent) operted some form of forml overdrft progrm, either utomted, linked-ccount, or overdrft LOC (see Tble III-1). Among ll study popultion bnks, 40.5 per cent operted n utomted overdrft progrm, 62.1 percent linked-ccount progrm, nd 50.1 percent n overdrft LOC progrm. 15 percent of bnks hd no forml overdrft progrm in plce, indicting tht NSF trnsctions were processed on n d hoc, discretionry bsis. Tble III-1 Number of Study Popultion Bnks Percent of Column Totl Did your institution operte this progrm t ny point in 2006 or 2007? b (Multiple nswers llowed) Forml Overdrft Progrms Operted All $250 Million $250 Million to By Asset Size Greter thn to $5 Billion Memo Item(s): Greter thn $5 Billion Automted Linked ccounts Overdrft LOC progrms Totl study popultion bnks 1, Memo Item(s): Number of bnks with 1, one or more forml overdrft progrm(s) Percent of ll study popultion bnks Figures do not lwys reconcile to totls due to the rounding of survey institutions weighted to represent the popultion. b Percentge shres do not sum to percent becuse ll nswers tht pply re included. FDIC November Study 2008 of Bnk Overdrft Progrms n November

15 Prt One Overdrft Survey III. Overview of Overdrft Progrms Tble III-2 Number of Study Popultion Bnks Percent of Column Totl Did your institution operte this combintion of progrms t ny point in 2006 or 2007? Menu of Overdrft Progrms Operted All $250 Million By Asset Size $250 Million to Greter thn Automted, linked, nd LOCs Automted nd linked Automted nd LOCs Automted only Linked nd LOCs Linked only LOCs only No forml progrm only b Totl study popultion bnks 1, Figures do not lwys reconcile to totls due to the rounding of survey institutions weighted to represent the popultion. b No forml progrm refers to NSF/overdrft items not processed under utomted overdrft, linked-ccount, or overdrft LOC progrms. Even mong bnks with forml overdrft progrms, however, NSF trnsctions could be processed on n d hoc bsis. 4 Lrge bnks tended to provide fuller menu of overdrft progrms, with 50.0 percent of lrge bnks operting ll three forml progrms (utomted, linked-ccount, nd overdrft LOC) (see Tble III-2). In contrst, most smll bnks (59.9 percent) operted only one progrm or no forml overdrft progrm t ll. While the shre of ll study popultion bnks with n utomted overdrft progrm ws 40.5 percent, significntly greter shre of lrge bnks (76.9 percent) hd n utomted progrm, compred with 65.2 percent of medium bnks nd 29.7 percent of smll bnks (see Tble III-1). The 83 lrge bnks tht operted n utomted overdrft progrm ccounted for 72.6 percent of ll trnsction ccount deposit dollrs held in the study popultion bnks, which suggests tht the mjority of ccounts in the study were held in bnks with n utomted progrm. 5 As mentioned in the methodology section, utomted overdrft progrms cn be promoted or nonpromoted. Promoted progrms re ctively offered to customers, while nonpromoted progrms re implemented without notifiction to the customer. Institutions with nonpromoted utomted progrms re not subject to certin disclosure requirements under Regultion DD of the Truth in Svings Act tht 4 For instnce, if n ccount covered by n overdrft LOC progrm exceeded the overdrft credit limit, the NSF trnsction might not be processed under the forml overdrft LOC progrm, nd the decision to py or return the NSF trnsction would be mde on n d hoc bsis. 5 Deposit dollrs for ech of the surveyed institution s checking, negotible order of withdrwl (NOW), nd money mrket demnd (MMD) ccounts were totled from the 2006 Cll Reports. FDIC Study of Bnk Overdrft Progrms n November

16 Prt One Overdrft Survey III. Overview of Overdrft Progrms Tble III-3 Number of Study Popultion Bnks Percent of Column Totl Did your institution operte promoted or nonpromoted utomted progrm? Promoted nd Nonpromoted Automted Progrms All $250 Million $250 Million to By Asset Size Greter thn to $5 Billion Memo Item(s): Greter thn $5 Billion Promoted b Nonpromoted only Totl with utomted Figures do not lwys reconcile to totls due to the rounding of survey institutions weighted to represent the popultion. b Fourteen institutions operted both promoted utomted nd nonpromoted utomted progrm. These institutions re included only in the promoted totl. pply to institutions tht promote the pyment of overdrfts. 6 Among study popultion bnks with utomted overdrft progrms, the mjority (78.9 percent) hd promoted progrm in plce (see Tble III-3). 7 Reltive to ll study popultion institutions, 31.9 percent of the institutions hd promoted utomted progrm, nd 8.5 percent operted nonpromoted progrm (see Figure III-1). Despite the lrger proportion of study popultion bnks with promoted utomted progrms, n nlysis of the dollr mount held in trnsction ccounts of study popultion bnks suggests tht greter proportion of consumer ccounts were likely covered by nonpromoted rther thn by promoted utomted progrms. More thn hlf (51.7 percent) of the trnsction ccount dollrs held in study popultion bnks were mintined in institutions with nonpromoted utomted progrms (see Figure III-2). 8 This finding is driven by the fct tht nonpromoted utomted progrms were more prevlent (63.3 percent) mong the lrgest study popultion bnks, those with more thn $5 billion in ssets. These 19 institutions ccounted for 45.1 percent of the trnsction ccount dollrs held in ll study popultion bnks. Figure III-1 Distribution of Study Popultion, by Automted Overdrft Progrms Operted 31.9% Figure III-2 Distribution of Trnsction Account Dollrs Held in Study Popultion by Automted Progrms Operted 16.1% 32.3% 59.5% 8.5% 51.7% Promoted utomted Nonpromoted utomted only No utomted progrm Promoted utomted Nonpromoted utomted only No utomted progrm 6 See 12 C.F.R See lso Finl Rule, 70 Fed. Reg (My 24, 2005). 7 Fourteen institutions hd both promoted nd nonpromoted utomted overdrft progrms, nd s result they were counted in the promoted ctegory. 8 Deposit dollrs for ech of the surveyed institution s checking, NOW, nd MMD ccounts were totled from the 2006 Cll Reports. FDIC Study of Bnk Overdrft Progrms n November

17 Prt One Overdrft Survey III. Overview of Overdrft Progrms Tble III-4 Number of Study Popultion Bnks Percent of Column Totl Did your institution dopt this overdrft progrm by 2001? Bnks with Forml Overdrft Progrm Implemented by 2001 All $250 Million By Asset Size $250 Million to Less thn Greter thn Automted Totl with utomted Linked ccounts Totl with linked ccounts Overdrft LOC progrms Totl with overdrft LOC progrms Figures do not lwys reconcile to totls due to the rounding of survey institutions weighted to represent the popultion. Survey results show tht the number of institutions in the study popultion providing utomted overdrft progrms hs grown rpidly in the pst severl yers. Most study popultion bnks with utomted progrms (68.4 percent) initited their progrm fter 2001 (see Tble III-4). Lrge bnks were erly dopters; more thn hlf (55.4 percent) hd n utomted progrm in plce by 2001, compred with 41.9 percent of medium bnks nd 18.2 percent of smll bnks. In contrst, the mjority of study popultion bnks tht operted linked ccounts nd overdrft LOCs lredy hd these progrms in plce by 2001 (89.4 percent nd 85.9 percent, respectively). III.2. Account nd Trnsction Coverge Surveyed institutions were sked which retil customer ccounts nd trnsction types were covered under ech overdrft progrm operted, whether n ccount could be covered by more thn one overdrft progrm, nd the order by which pplicble overdrft progrms pplied to the ccount. The three min types of trnsction ccounts covered by overdrft progrms re checking ccounts, negotible order of withdrwl (NOW) ccounts, nd money mrket demnd (MMD) ccounts. 9 Of bnks in the study tht operted n utomted progrm, ll bnks (100.0 percent) covered checking ccounts, while the mjority (74.9 percent) covered NOW ccounts, nd bout third (32.2 percent) covered MMD ccounts (see Tble III-5). Similrly, lmost ll institutions (99.3 percent) tht operted linked-ccount progrm covered checking ccounts, while sizble mjorities lso covered NOW nd MMD ccounts. All institutions (100.0 percent) tht operted overdrft LOC progrms covered checking ccounts, nd mny lso covered NOW nd MMD ccounts. Of the 584 study popultion bnks tht operted more thn one overdrft progrm, the mjority (71.8 percent) llowed n ccount to be covered by more thn one overdrft progrm (see Tble III-6). Of these 419 bnks with multiple progrms tht llowed multiple coverge, 261 (62.2 percent) operted n utomted overdrft progrm, while the reminder hd only linked-ccount nd n overdrft LOC progrm. For the vst mjority (95.8 percent) of these 261 bnks, overdrft coverge under linked- 9 Although surveyed institutions were sked whether the overdrft progrms covered svings ccounts, these ccounts were not included in the nlysis becuse they re typiclly not the trnsction ccounts by which third prties re pid. Retil bnking customers typiclly withdrw funds from nd mke pyments with their checking ccounts; thus, overdrft progrms re most relevnt for this type of ccount. FDIC Study of Bnk Overdrft Progrms n November

18 Prt One Overdrft Survey III. Overview of Overdrft Progrms Tble III-5 Number of Study Popultion Bnks Percent of Column Totl Accounts Covered by Forml Overdrft Progrms By Overdrft Progrms Offered For which of the following ccounts did your institution offer the progrm? (Multiple nswers llowed) Automted Linked-Account Overdrft LOC Checking NOW MMD Totl with progrm Percentge shres do not sum to percent becuse ll nswers tht pply re included. Tble III-6 Number of Study Popultion Bnks Percent of Column Totl Did your institution llow n ccount to be covered by more thn one overdrft progrm? Account Coverge by Multiple Overdrft Progrms All $250 Million By Asset Size $250 Million to Greter thn No Yes Totl tht operted more thn one progrm Hd utomted Did not hve utomted Totl tht operted more thn one progrm nd llowed multiple coverge Figures do not lwys reconcile to totls due to the rounding of survey institutions weighted to represent the popultion ccount or n overdrft LOC progrm pplied to the ccount first, before the utomted progrm (see Tble III-7). In 4.2 percent of the cses, therefore, n overdrft would be covered by the utomted progrm before ny linked-ccount or overdrft LOC progrm pplied. Further, despite invoking linked-ccount or n overdrft LOC progrm first, 9.0 percent of these institutions operted ll three progrms, but invoked their utomted progrm second rther thn third. Regrding trnsction coverge, overdrft progrms cn cover four brod ctegories of trnsctions: pper checks or equivlents, utomted teller mchine (ATM) trnsctions, point-of-sle (POS)/debit trnsctions, nd utomted clering house (ACH) trnsctions. 10 The mjority (80.5 percent) of institutions tht operted n utomted progrm covered ll four ctegories (see Tble III-8). Most of the study 10 Equivlents re trnsctions tht strted off s pper check for exmple, wrrnt, teller check, or check tht customer presents to store to be scnned lter. The customer expects tht the pyment will be processed like regulr check. ACH trnsctions include, for exmple, electronic bill pyments nd utomtic debits. FDIC Study of Bnk Overdrft Progrms n November

19 Prt One Overdrft Survey III. Overview of Overdrft Progrms popultion bnks with utomted progrms (81.0 percent) llowed overdrfts for ATM nd POS/debit trnsctions. Similrly, more thn 80.0 percent of bnks with linked-ccount or n overdrft LOC progrm covered ll four trnsction types, including ATM nd POS/debit. Tble III-7 Number of Study Popultion Bnks Percent of Column Totl In wht order did your institution invoke customer s pplicble overdrft progrms? Three progrms Order Overdrft Progrms Invoked All $250 Million By Asset Size $250 Million to By Type of Automted Progrm Greter thn Nonpromoted Promoted Linked nd LOC before utomted b Linked or LOC before utomted b Automted before linked nd LOC Two progrms Linked or LOC before utomted b Automted before linked or LOC Totl tht operted more thn one progrm, llowed multiple coverge, nd hd utomted Figures do not lwys reconcile to totls due to the rounding of survey institutions weighted to represent the popultion. b Fourteen institutions tht reported only tht they invoked their linked-ccount then their overdrft LOC progrm lso operted n utomted overdrft progrm. Four institutions tht reported tht they invoked their linked-ccount then utomted overdrft progrm lso operted n overdrft LOC progrm. It is presumed tht the omitted progrm ws invoked lst. Tble III-8 Number of Study Popultion Bnks Percent of Column Totl Trnsctions Covered by Forml Overdrft Progrms By Overdrft Progrms Offered Which trnsctions were covered by your institution s progrm in the event of n overdrft? (Multiple nswers llowed) Automted Linked-Account Overdrft LOC Checks, ATM, POS/debit, nd ny ACH ATM nd POS/debit Totl with progrm Percentge shres do not sum to percent becuse ll nswers tht pply re included. FDIC Study of Bnk Overdrft Progrms n November

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