Questionnaire

FDIC Overdraft Protection Survey I
Institution Programs and Practices
Final Version: January 22, 2007

Table of Contents
Page
Definitions

ii

Survey I Completion

iii

I. GENERAL & AGGREGATE
A. Scope of Services

1

B. Aggregate Income

2

C. General Processing Practices

3

D. Program Selection

4

II. PROGRAM SPECIFIC
A. Policies

5

B. Monitoring

6

C. Information Provided to Consumers

7

D. Fees

9

E. Account Coverage

10

F. Vendors

11

Comments

13

Definitions
A. Programs
(1) Linked Transfer Accounts
A contractual agreement between a bank and a customer, linking the customer’s transactions account with other
accounts within the bank, including savings and credit card accounts. In the event of an overdraft, the bank will
fulfill the customer’s obligations by transferring funds from the customer’s other accounts linked to his transactions
account.
(2) Overdraft Lines of Credit
A contractual agreement between a bank and a customer that the bank is willing to lend up to a specified amount
over a specified future period to cover overdrafted items. These programs DO NOT include line of credit programs
that do not specifically cover overdrafted items, for example, home equity lines of credit. The bank extends the line
of credit after reviewing a customer using standard underwriting criteria; the line is considered a loan and requires
standard Truth-in-Lending (Regulation Z) disclosures.
(3) Automated Promoted Overdraft Protection
A program or policy where a bank generally honors a customer’s overdrafted obligations, and customers ARE
informed of the existence of the overdraft protection program. The program is uniformly offered to qualifying
customers. Excluded are all overdraft programs where an APR is required. The program is automated in the sense
that standardized procedures or a "matrix" is used to determine whether the NSF item qualifies for the overdraft
protection. Automated programs are typically, but not necessarily, computerized.
(4) Automated Non-Promoted Overdraft Protection
A program or policy where a bank generally honors a customer’s overdrafted obligations; however, customers are
NOT informed of the existence of the overdraft protection program. The program is automated in the sense that
standardized procedures or a "matrix" is used to determine whether the NSF item qualifies for the overdraft
protection. Automated programs are typically, but not necessarily, computerized.
(5) Non-Automated Non-Promoted Ad Hoc Overdraft Protection
These include truly incidental and discretionary accommodations to customers by banks to honor overdrafted items.
These decisions are made independent of or override the programs described in (1) through (4).
B. Terms
Grace Period – The period of time an account holder has to bring an overdrafted account back to a positive
balance without incurring any fees other than the initial per item/per occurrence fee.
Initiation Fee vs. Maintenance Fee – An initiation fee is a one time charge to begin/establish a customer in a
program. A maintenance fee is a recurring fee to maintain the customer in the program. It is typically a monthly or
annual fee.
Overdraft Item vs. Occurrence – For example, if a customer had two bounced checks in a given day and was
charged two separate fees, that would be considered a fee “per item.” On the other hand, if the customer was
charged one lump sum to cover both checks in the same day, that would be considered a fee "per occurrence.”
Workout Phase – When a customer cannot return an account to a positive status and works with the bank to
develop a repayment schedule.

Final Version: January 22, 2007
ii

Survey I
A. Institution

Bank Name
Headquarter City
Headquarter State
Region
FDIC Certificate Number
B. FDIC

Examiner Name
Examination Type
Examination Date
Survey I Completion Date
C. Coverage
As of July 1, 2006, was the institution
subject to the revisions of Regulation DD?

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Final Version: January 22, 2007

I. General
A. Scope of Services
Section IA determines to what extent portions of this survey are relevant to the institution depending on
what overdraft options it offers or offered in 2006 . For questions IA1, IA2, IA3, and IA4, each “Yes” answer
indicates that a subsequent subsection in Section II, "Program Specifics," related respectively, to (1) linked
transfer accounts, (2) overdraft lines of credit, (3) automated promoted overdraft protection, and (4)
automated non-promoted overdraft protection, is to be completed. Please refer to page ii for definitions for
Programs (1) through (4).
1. Does the institution offer linked transfer accounts, or offered it at any point in 2006? If yes,
please answer the questions using column (1) for all subsections of Section II. 1 = Yes, 2 = No.
1.1 If the institution initiated the program within the last five years , please specify the month and year
in which the institution initiated the program.
a. Month (MM)
b. Year (YYYY)
1.2 If the institution terminated the program in 2006 , please specify the month and year in which the
institution terminated the program.
a. Month (MM)
b. Year (YYYY)
1.3 If yes to Question 1, please describe below the institution's program.
2. Does the institution offer overdraft lines of credit, or offered it at any point in 2006? If yes, please
answer the questions using column (2) for all subsections of Section II. 1 = Yes, 2 = No.
2.1 If the institution initiated the program within the last five years , please specify the month and year
in which the institution initiated the program.
a. Month (MM)
b. Year (YYYY)
2.2 If the institution terminated the program in 2006 , please specify the month and year in which the
institution terminated the program.
a. Month (MM)
b. Year (YYYY)
2.3 If yes to Question 2, please describe below the institution's program.
3. Does the institution offer automated promoted overdraft protection, or offered it at any point in
2006? If yes, please answer the questions using column (3) for all subsections of Section II. 1 = Yes,
2 = No.
3.1 If the institution initiated the program within the last five years , please specify the month and year
in which the institution initiated the program.
a. Month (MM)
b. Year (YYYY)
3.2 If the institution terminated the program in 2006 , please specify the month and year in which the
institution terminated the program.
a. Month (MM)
b. Year (YYYY)
3.3 If yes to Question 3, please describe below the institution's program.
4. Does the institution extend automated non-promoted overdraft protection, or did so at any point
in 2006? If yes, please answer the questions using column (4) for all subsections of Section II. 1 =
Yes, 2 = No.
4.1 If the institution initiated the program within the last five years , please specify the month and year
in which the institution initiated the program.
a. Month (MM)
b. Year (YYYY)
4.2 If the institution terminated the program in 2006 , please specify the month and year in which the
institution terminated the program.
a. Month (MM)
b. Year (YYYY)
4.3 If yes to Question 4, please describe below the institution's program.
5. Does the institution have any other overdraft program that does not meet the descriptions of
programs (1) through (4) described under "Definitions - A. Programs"? 1 = Yes, 2 = No.
5.1 If yes, please describe below this program.

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Final Version: January 22, 2007

I. General
B. Aggregate Income & Losses
1. For each year below, what was the TOTAL dollar amount of the institution's total gross income from all
fees related to NSF items? This includes fee income for paid overdrafted items, for returned overdrafted
items, from initiation fees, and from maintenance fees.
1.1

2006

1.2

2005

1.3

2004*

1.4

2003*
2002*

1.5

2.* For each year below, what was the dollar amount of the institution's total gross income from per item/
per occurrence PAID NSF items? This excludes fee income for returned overdrafted items, initiation fees,
and maintenance fees.
2.1
2006
2.2
2005
2.3
2004
2.4
2003
2.5
2002
3.* For each year below, what was the dollar amount of the institution's total gross income from per item/
per occurrence RETURNED NSF items? This excludes fee income for paid overdrafted items, initiation
fees, and maintenance fees.
3.1
2006
3.2
2005
3.3
2004
3.4
2003
3.5
2002
4. How many deposit
accounts were charged
off in 2006?
5. What was the total
dollar amount of these
charge-offs?
6. How many deposit
accounts were
converted to workout
loans in 2006?
7. What was the total
dollar amount of these
workout loans?
*

Note: If data readily available.

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Final Version: January 22, 2007

I. General
C. General Processing Practices
1. In what order are transactions typically paid? (Please rank beginning from “1” and mark “NA” if
not applicable.)
a. Cash transactions (e.g. teller services)
b. In-house ATM transactions
c. System ATM transactions
d. On us
e. Online payments
f. ACH
g. POS
h. Other (please describe below)

2. For those items which the institution batch processes, which method best describes in what
order transactions are typically paid?
1 = By size, starting with largest
2 = By size, starting with the smallest
3 = By check number
4 = By order of presentation
5 = Other (please describe below)

3. If an account is covered by two or more of the (1) through (4) overdraft protection programs
described under “Definitions - A. Programs,” please rank the order in which a customer’s applicable
overdraft protection programs are invoked. (Please rank beginning from “1” and mark “NA” if not
offered.)
a. Linked Transfer Accounts
b. Overdraft Lines of Credit
c. Promoted Overdraft Protection
d. Automated Non-Promoted Overdraft Protection
3.1 If necessary, please make comments below.

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Final Version: January 22, 2007

I. General
D. Program Selection
1. How does the institution determine which overdraft protection program to offer new customers?
1 = Offers all programs available for the type of account
2 = Uses software to determine which customers are offered which programs
3 = Offers only automated promoted overdraft protection unless other options solicited by
customer
4 = Other (please describe below)

2. Does the institution provide information that allows consumers to compare the features and
costs of alternative types of overdraft protection? 1 = Yes, 2 = No
2.1 If yes, with what means are customers informed of alternative types of overdraft protection
offered by the institution? (Mark each that applies.)
a. Deposit account agreement
b. Brochure about accounts
c. Bank personnel informs customers
d. Do not inform customers
e. Other (please describe below)

3. Does the institution offer any educational information that helps customer use overdraft
protection wisely/efficiently? 1 = Yes, 2 = No
3.1 If yes, with what means are customers assisted in selecting an overdraft protection program?
(Mark each that applies.)
a. Comparison chart
b. Fee sheets
c. Example of costs
d. Overdraft protection brochure
e. Other (please describe below)

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Final Version: January 22, 2007

II. Program Details

A. Policies

(1)

(2)

Linked
Transfer
Accounts

Lines of
Credit

(3)

(4)

(5)
NonAutomated
Automated
NonAutomated
NonPromoted
Promoted Promoted
Ad Hoc
Overdraft Overdraft Overdraft
Protection Protection Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

1. Has the institution adopted written policies and
procedures to address the operational and other risks
associated with the program?
1 = Yes, 2 = No
1.1 If yes, does this policy set a cap on the total dollar
amount of advances per customer that the bank will
extend through the program, which is consistent with the
institution’s ability to absorb losses?
1 = Yes, 2 = No
1.1.1 If yes, what is that dollar limit?
1.2 What other features of the program are established
in this written policy? (Mark each that applies.)
a. All associated fees
b. APR
c. The process for providing disclosures to customers
d. A timeline of customer notification
e. positive
f. A timeline for charge-off of unpaid advances
g. Workout loan procedures
h. Other (please describe below)

2. Was this program reviewed for compliance with
applicable laws prior to implementation? (Mark each that
applies.)
a. Yes, by bank counsel
b. Yes, by independent counsel
c. Yes, by bank management only (no counsel)
d. Yes, by bank board
e. Not reviewed
f. Other (please describe below)

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Final Version: January 22, 2007

II. Program Details
(1)

Linked
Transfer
Accounts
B. Monitoring

(2)

Lines of
Credit

(3)

(4)

Automated
Automated
NonPromoted Promoted
Overdraft Overdraft
Protection Protection

(5)
NonAutomated
NonPromoted
Ad Hoc
Overdraft
Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

1. Does the institution maintain customer-level information
about usage, and fees and interest accrued under the
particular overdraft program?
1 = Yes, 2 = No
2. How many times in 2006 did senior management
evaluate the program, including items such as reviewing
overdraft activity, heavy usage, income and losses?
3. What best describes how the institution monitors and
evaluates the performance of the program?
1 = Vendor provides reports
2 = Self evaluation
3 = Hire consultant to conduct evaluation
4 = Do not regularly evaluate
5 = Other (please describe below)

4. Does the institution monitor the program for extensive
usage?
1 = Yes, 2 = No

4.1 If yes, please describe.
5. In 2006, did the institution ever NOT cover an NSF item
for a customer in good standing, where there were
sufficient funds within the institution's policy limits?
6. In 2006, how many complaints were received by the
institution for the particular program?

6

Final Version: January 22, 2007

II. Program Details
(1)

Linked
Transfer
Accounts
C. Information Provided to Consumers

(2)

(3)

(4)

Lines of
Credit

Automated
Promoted
Overdraft
Protection

Automated
NonPromoted
Overdraft
Protection

(5)
NonAutomated
NonPromoted
Ad Hoc
Overdraft
Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

1. When does the institution inform its customers of
the program? (Mark each that applies.)
a. When account is opened
b. Periodically with account updates
c. When asked by customer
d. Do not inform customers
e. Other (please describe below)

2. What is the primary means by which customers
are informed of the features of the program?
1 = Deposit account agreement
2 = Brochure about accounts
3 = Bank personnel informs customer
4 = Letter or special mailing to customer
5 = Do not inform customers
6 = Other (please describe below)

3. Which features are customers informed of when
they enroll or are included in the program? (Mark
each that applies.)
a. The schedule of fees charged
b. APR
c. Which transactions are covered
d. How transactions are processed in
determining account balances and fees
e. The available dollar limit covered
f. Other (please describe below)

4. Do balances provided at proprietary ATM’s show
the overdraft coverage limit?
1 = No, the overdraft limit is not shown in any
ATM balance
2 = Yes, the overdraft limit is included in the only
balance shown
3 = Yes, the overdraft limit is shown but listed
separately from the actual balance

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Final Version: January 22, 2007

(1)

Linked
Transfer
Accounts
C. Information Provided to Consumers, con't
5. Do balances provided at non-proprietary ATM’s
show the overdraft coverage limit?
1 = No, the overdraft limit is not shown in any
ATM balance
2 = Yes, the overdraft limit is included in the only
balance shown
3 = Yes, the overdraft limit is shown but listed
separately from the actual balance
4 = Do not know

(2)

(3)

(4)

Lines of
Credit

Automated
Promoted
Overdraft
Protection

Automated
NonPromoted
Overdraft
Protection

(5)
NonAutomated
NonPromoted
Ad Hoc
Overdraft
Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

6. When an ATM transaction results in an NSF,
when is the customer notified?
1 = At the time of the transaction, prior to
completion of the transaction
2 = At the time of the transaction, after the
completion of the transaction
3 = Subsequent to the time of transaction (e.g. via
customer notification such as mail or email)
4 = Other (please describe below)

7. When a POS transaction results in an NSF,
when is the customer notified?
1 = At the time of the transaction, prior to
completion of the transaction
2 = At the time of the transaction, after the
completion of the transaction
3 = Subsequent to the time of transaction (e.g. via
customer notification such as mail or email)
4 = Other (please describe below)

8. In 2006, how many times did the institution
advertise in print, radio, or television?
8.1 If the institution had print, radio, or television
advertisements, how many featured the program?
8.2 Of these advertisements which featured the
program, how many were primarily to promote the
program or prominently featured the program?
9. In 2006, of all the institution's customer mailings,
how many primarily or prominently featured the
program?

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Final Version: January 22, 2007

II. Program Details
(1)

Linked
Transfer
Accounts
D. Fees
1. What is the initiation fee associated with the program?
(If none enter $0.)

(2)

Lines of
Credit

(3)

(4)

Automated
Automated
NonPromoted Promoted
Overdraft Overdraft
Protection Protection

(5)
NonAutomated
NonPromoted
Ad Hoc
Overdraft
Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

2. What is the maintenance fee to maintain the program?
(If none enter $0.)
2.1 How often is this fee assessed?
1 = Monthly
2 = Yearly
3 = Other
3. How are overdraft items charged?
a. Per item
b. Per daily occurrence
c. Other (please describe below)

4. Fees and interest charged:
4.1 For the institution's linked accounts and lines of credit
programs, what is the fee to transfer or advance funds?
4.2 For the institution's lines of credit program, what is
the typical APR on the outstanding balance?
4.3 What is the fee charged to PAY an NSF item?
4.4 What is the fee charged to RETURN an NSF item?
5. Does the per item/occurrence fee change with the
number of items/occurrences with insufficient funds?
1 = Yes, 2 = No

5.1 If yes, please describe the program's fee schedule.
6. How are overdraft funds typically
1 = As needed to meet overdrafts
2 = As needed with a minimum draw
3 = Round lots
4 = Other
6.1 If “Round lots” was chosen, in what denomination are
the round lots? (e.g. $50, $100)
7 Once an account is overdrawn, are additional fees or
interest assessed subsequent to regular per item/per
occurrence fees for being in overdraft status?
1 = Yes, 2 = No

7.1 If yes, please describe.
7.2 Is yes, what is the grace period before the additional
fees are charged, in days?
8 In the context of fees, does the institution define days
by: 1 = Business Days, 2 = Calendar Days

9

Final Version: January 22, 2007

II. Program Details
(1)

Linked
Transfer
Accounts
E. Account Coverage

(2)

(3)

(4)

Lines of
Credit

Automated
Promoted
Overdraft
Protection

Automated
NonPromoted
Overdraft
Protection

(5)
NonAutomated
NonPromoted
Ad Hoc
Overdraft
Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

1. For which of the following accounts is the
program offered? (Mark each that applies.)
a. Checking
b. Money Market
c. NOW
d. Savings
2. Which transactions are covered by the program
in the event of an overdraft?
a. Paper checks/Equivalents
b. ATM withdrawals
c. Debit cards/POS
d. Electronic billpay
e. Automated debit
f. ACH
g. Other (please describe below)

3. Is the program:
1 = Completely Opt-in
2 = Completely Opt-out
3 = Other (please describe below)

4. In 2006:
4.1 How many accounts opted in to the program?
4.2 How many accounts opted out of the program?
5. What rules/procedures are used to determine
whether a customer qualifies for the program?
(Mark each that applies.)
a. Credit check
b. Minimum balance
c. Age of account
d. History with institution
e. Recurring deposit (e.g. direct deposit)
f. Other (please describe below)

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Final Version: January 22, 2007

II. Program Details

F. Vendors
1. Is the institution’s current overdraft program
implemented/managed by a vendor or other third party?
1 = Yes, 2 = No

(1)

(2)

Linked
Transfer
Accounts

Lines of
Credit

(3)

(4)

(5)
NonAutomated
Automated
NonNonAutomated
Promoted
Promoted Promoted
Ad Hoc
Overdraft
Overdraft
Overdraft
Protection Protection Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

If the answer to Question 1 is “Yes,” please answer the following vendor-related questions below.
2. How long has the institution used a vendor-supplied
program, in months (MM)?
3. What was the original term of the institution's current
contract with the vendor, in months (MM)?
4. Which of the following best describes the institution’s
program?
1 = A standardized program obtained from a vendor
(off-the-shelf)
2 = A customized program obtained from a vendor
where the institution sets the program’s
parameters
3 = Other (please describe below)

5. Did the institution first establish or expand its
overdraft protection program with the adoption of a
vendor program?
1 = Yes, 2 = No
6. Which vendor does the institution use?
1 = Allied Solutions Group Inc.
2 = Fiserv Inc
3 = Impact Financial Services
4 = Jack Henry
5 = John M. Floyd & Associates
6 = MEA Financial Services
7 = Moebs $ervices Inc.
8 = Pinnacle Financial Strategies
9 = Strunk & Associates L.P.
10 = Other (please list below)

7. Does the vendor receive a percentage of
income/fees generated by the product?
1 = Yes, 2 = No

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Final Version: January 22, 2007

F. Vendors, con't

(1)

(2)

Linked
Transfer
Accounts

Lines of
Credit

(3)

(4)

(5)
NonAutomated
Automated
NonNonAutomated
Promoted
Promoted Promoted
Ad Hoc
Overdraft
Overdraft
Overdraft
Protection Protection Protection

Complete this section if you answered “Yes” for Question:
IA1
IA2
IA3
IA4
IA5

7.1 If yes, in 2006, what share of fees (in %, e.g. 15, 25)
from the institution's overdraft protection program was
the vendor paid?
8. Does the vendor's compensation depend on a
minimum level of usage by bank customers?
1 = Yes, 2 = No
9. Does the vendor’s compensation depend on features
of the program such as its fee structure or how
transactions are cleared?
1 = Yes, 2 = No

12

Final Version: January 22, 2007

Comments
The space below is provided for any additional comments the institution may desire to make regarding its
overdraft protection policies, programs and practices.

13

Draft Version: January 22, 2007