On November 12th the Federal Reserve announced changes to Regulation E that will substantially impact practices regarding consumer overdrafts. These overdrafts represent $25 - $30 BN per year in depository revenue. Given the recent regulatory and legislative tone, the amendments are not wholly surprising, and most institutions were already considering strategic options for a future without some of these fees. The timeline, however, has come as somewhat of a shock, with substantial change required by July 1, 2010. Depending on your starting point, this change will likely require significant operational effort across communications, product development, technology and risk management - as well as a continued push towards strategic transformation.
