Compliance Blog

Oct 24, 2007
Categories: Board and Governance

A Little ODP, from the BOA

NAFCU has a wonderful service for members.  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.  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.  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.  BOA.

Question: Does my credit union’s board of directors need to approve our credit union’s overdraft protection (bounce protection) program?

Answer: According to NCUA’s Automated Integrated Regulatory Examination Software (AIRES), yes. NCUA’s regulations permit credit unions to establish bounce protection programs. 12 C.F.R. § 701.21(c)(3). While this regulation does not indicate whether a credit union’s 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: “Has the board of directors established a written policy addressing the payment of overdrafts through bounce protection?” You can access 05-CU-21 at:
(February 2007.)