Wednesday, May 7, 2014

Large CUs Should Report Overdraft Program Revenues

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."

Credit unions with $1 billion or more in assets should begin to report revenues related to their overdraft programs. There is not any policy justification for excluding these large credit unions from reporting this data.

The decision to exclude credit unions from the data collection project renders hollow the Consumer Financial Protection Bureau's claim that they will be a data driven agency. When it comes to credit unions, this agency seems to wear rose-colored glasses.


  1. Remember the price controls in Massachusetts. It won't be long now and the CFPB will have the data it needs to impose the same thing nationally. Then we will be forced to impose fees for the checking account in order to maintain revenue levels.

    1. So, you admit that you gouge the unsuspecting for little mistakes to offer 'free' checking services, and increase revenue. Nice. Wonder if you have the same worries about controlling your expenses (salaries).

  2. I am a credit union true believer and often don't agree with everything you write, but this is a "no-brainer" and adding the reporting requirement would not be an undue burden and would eliminate this question/controversy.



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