June 30, 2023 at 4:36 pm EDT #341579TheBankParticipant
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?July 9, 2023 at 8:22 am EDT #341635Kimberly Boatwright, CAMS, CRCMKeymaster
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.
NOTICE: This email message, including any attachments, is intended only for the addressee, and may contain confidential and privileged information either as protected work product or confidential client information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, do not read, copy, retain, or disseminate this message or any attachment, and please contact the sender by reply e-mail or at 888.760.5646 and destroy all copies of the original message and attachments. Neither the transmission of this message or any attachment, nor any error in transmission or misdelivery shall constitute waiver of any applicable legal privilege.
THIS EMAIL AND ITS ATTACHMENTS DO NOT CONSTITUTE LEGAL ADVICE
- You must be logged in to reply to this topic.