2025 Pub. 6 Issue 4

With rising consumer expectations, growing competition and ongoing economic uncertainty, banks can no longer rely on outdated, one-size-fits-all overdraft programs or legacy small-dollar loan offerings. Yet many institutions are still using ad hoc or legacy systems that lack transparency, adaptability and actionable insight. If your overdraft system assigns limits or manages old-school loan risk without your team understanding the logic behind those decisions — it is time to ask the tough questions. Today’s Landscape Demands More Regulatory agencies like the CFPB, FDIC, OCC, state regulators and others are sharpening their focus on fairness, transparency and consistency in overdraft and liquidity practices. At the same time, customers expect financial institutions to deliver personalized and equitable service. Ask yourself: • Do we have a strategy to attract profitable consumers who seek new forms of liquidity? • Can we explain, defend and adjust our overdraft decisions in real time? • Is our approach helping customers stay banked — not driving them away? • Do we offer loan options underwritten by deposit behavior? • Do we understand who is recovering from overdraft use — and who is not? If your answer is “no,” you are not alone — but now’s the time to act. Data Is Only Powerful When It is Actionable Banks sit on enormous amounts of valuable data — deposit trends, transaction behaviors, fees and recovery rates. But if your system IS IT TIME TO REALIGN YOUR BY TIM BARRETT, EXECUTIVE DDA STRATEGIES, CSI LEGACY CONSUMER LIQUIDITY STRATEGY? Yes — Now More Than Ever 16 In Touch

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