Large credit unions should report overdraft program

by. Keith Leggett

Beginning with the March 31, 2015 Call Report, banks with at least $1 billion in assets will be required to report revenues from consumer overdraft-related service charges.

This change in the call report arose from the Consumer Financial Protection Bureau’s desire to develop an understanding of market-wide behavior and activity with regard to overdraft protection programs.

In a 2013 letter, the American Bankers Association, the Financial Services Roundtable, and the Consumer Bankers Association noted that “using the Call Report process creates a significant data gap in that it excludes a significant number of deposit-like products from non-bank financial institutions.”

The joint trade associations wrote:

“[I]t is not clear why credit unions which are widely engaged in overdraft protection programs and whose mission is serving the consumer market – were left out of the reporting process even though their regulator is both an FFIEC member and a Federal financial institution regulatory agency.”

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