[TheBank]

I am looking at our total NSF and overdraft fee income as a percent of our total non interest income. What is an acceptable level for that percentage? Is there any guidance on that, or a place that publishes that information? Should we be looking at that income type and relating it to total non interest income, or service charge income? I am looking at this because it is one of the tools that has been mentioned when looking at our NSF and OD program and fees due to the recent FDIC FIL and related pressures regarding those types of chages, and determining if it is a significant piece of our income. But what level is considered significant?

[Kimberly Boatwright, CAMS, CRCM]

There has been no guidance on what is “an acceptable level”. The only information that has been mentioned has been in enforcement actions where it was cited as having been a significant portion of an institutions fee income collected. Using the word significant is a subjective term without defining it for the industry, but unfortunately it hasn’t been. Do you belong or have a compliance networking group that you could pose this question to? They maybe able to provide some guidance if they have had conversations about this with their regulator. If you have a good relationship with your EIC you could also pose this question to them and see if they could provide guidance as well.

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