2026-2027 Pub. 16 Issue 1

• Is it monitored? • Is it aligned with customer needs? • Is it supported by training, reporting and ongoing oversight? When the answers are yes, overdraft can be more than a fee-based product. It can be a service that supports customers, strengthens operational discipline and helps banks navigate regulator expectations with greater confidence. Overdraft does not have to be a source of confusion or concern. When managed responsibly, it can be a structured service that customers value and use when needed. The opportunity for community banks is to move beyond outdated assumptions and manage overdraft with the same care, structure and focus they bring to every other important customer service. Contact us at advantage-fi.com/contact-us to explore how a service-focused approach can help your bank manage overdrafts with greater clarity, consistency and confidence. Cheryl Lawson is executive vice president of compliance review at ADVANTAGE. She helps community financial institutions navigate overdraft compliance, strengthen program oversight, and support responsible practices that align with regulatory expectations and consumer needs. monitored, it can support customers while helping the bank maintain responsible practices. That includes looking at questions such as: • How are customers informed about their options? • Are staff trained to explain the program clearly and confidently? • Are overdraft limits and practices aligned with the bank’s risk tolerance and customer needs? • Are reports reviewed regularly to identify trends, exceptions or areas of concern? • Are communications written in a way that customers can actually understand? These are not just compliance questions; they are service questions that influence whether overdraft is experienced as a helpful option or a source of frustration. Ongoing Oversight Supports Stronger Compliance Regulators continue to focus on fairness, transparency, consumer harm and whether financial institutions can demonstrate that their practices align with today’s program expectations. That makes documentation, training, monitoring and consistency more important than ever. When overdraft is managed as a service, compliance becomes part of the operating model — not a last-minute reaction to examiner feedback or regulatory pressure. It’s consistent execution across the organization that demonstrates a clear commitment to responsible practices. Responsible Design Strengthens Long-Term Performance A well-managed overdraft program can help protect non-interest income, support customer relationships, reduce confusion, improve staff confidence and strengthen the institution’s ability to respond to regulatory expectations. The programs that perform well are not necessarily the most aggressive. They are the ones built with structure, oversight, communication and customer experience in mind. That is where responsible design becomes a competitive advantage. The Conversation Around Overdraft Is Changing Overdraft remains a focus for regulators, consumer advocates and financial institutions, but the conversation does not have to be reduced to a binary question of whether overdraft is good or bad. The more useful question is whether the program is designed and managed responsibly. • Is it clear? • Is it consistent? 15 Colorado Banker

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