I believe most banks charge the same fee for NSFs and overdrafts. With that being said, IMO, if you had an automated program that customer could opt in/out of I wouldn’t see as much concern as I do with the ad hoc program since the customer would be agreeing to/authorizing the payment of overdrafts and the assessment of a higher fee. And even though you will be disclosing the change in fee, this type of program may encourage managers to approve overdrafts to increase fee income when perhaps customers may not quite meet your guidelines, which could be a UDAAP problem.
