A Little ODP, from the BOA
NAFCU has a wonderful service for members.Â It is our Book of Answers. (NAFCU Log-in needed.) We took the questions and answers from our monthly Compliance Newsletter and BSA Blast, and we organized them by subject matter.Â We have quite a few questions and answers. Fifty-two pages worth, to be exact. The Compliance Guy can't give this stuff away, as it is a NAFCU member benefit.Â And their dues help pay my salary, which pretty much all goes for popcorn at Nationals games. But for you non-NAFCU folks, here's a snippet of what the Book of Answers, a.k.a.Â BOA.
Question: Does my credit unionÃ¢ÂÂs board of directors need to approve our credit unionÃ¢ÂÂs overdraft protection (bounce protection) program?
Answer: According to NCUAÃ¢ÂÂs Automated Integrated Regulatory Examination Software (AIRES), yes. NCUAÃ¢ÂÂs regulations permit credit unions to establish bounce protection programs. 12 C.F.R. ÃÂ§ 701.21(c)(3). While this regulation does not indicate whether a credit unionÃ¢ÂÂs board of directors must approve such programs, NCUA clarified its expectations in this area when it issued Letter to Credit Unions 05-CU-21. The guidance introduced the new AIRES Payment of Overdrafts (Bounce Protection Questionnaire. Cell A-14 directs NCUA examiners to ask the following question: Ã¢ÂÂHas the board of directors established a written policy addressing the payment of overdrafts through bounce protection?Ã¢ÂÂ You can access 05-CU-21 at: http://www.ncua.gov/letters/letters.html.