does not adapt to risk, only provides canned reports, charges for peer benchmarking or hides key logic behind “proprietary” algorithms, you are flying blind. Worse, if you are applying the same limit to all accounts, you’re missing critical indicators of risk — and opportunity. A modern Consumer Liquidity small-dollar loan and overdraft program should: • React to individual account behavior daily. • Adjust limits automatically based on real activity. • Identify high-risk accounts before losses occur. • Offset risk from either the loan or overdraft use. This is not just about efficiency; it is about control, visibility and long-term customer relationships. Transparency Is Not Optional Anymore Can you explain how a customer’s overdraft limit was set this month versus last month? Do you know when their deposit patterns changed and what you did in response? Is your front-line staff comfortable with explaining options for informed decision-making? If not, your institution may be exposed to compliance and operational risk. A modern approach: • Trains front-line staff by experienced professionals. • Audits every account relationship daily. • Manages exception items automatically. • Documents decisions clearly for examiners. More importantly, it aligns with proven best practices and gives you the confidence to stand behind your program — regardless of who is asking. Consistency Builds Trust — Especially With Fee Refunds One of the most common struggles in overdraft programs is inconsistency in fee refund decisions. Without a structured approach, decisions often vary by branch, location or staff discretion — raising red flags and exposing your bank to bias claims or unfair treatment accusations. 17 In Touch
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