Protecting the privacy of our members is of utmost importance to us. Federal law requires that we give you this privacy notice which describes our privacy policy and practices concerning the personal information we collect and disclose about our members. Also included is information about the parties who necessarily receive personal and sometimes nonpublic information from us as we conduct the business of the credit union.
Collected Information About You
As permitted by law, we may disclose all the nonpublic information collected from the following sources:
- Information we receive from you on applications and other forms
- Information about your transactions with us
- Information we receive from a consumer reporting agency
- Information obtained when verifying the information you provide on an application or other forms. This may be obtained from your current or past employers or from other institutions where you conduct financial transactions.
Parties Who Receive Information From Us
Nonpublic personal information about you may be disclosed to the following types of third parties:
Financial service providers, such as insurance companies, and mortgage service companies
Non-financial companies, such as consumer reporting agencies, data processors, check/share draft printers, financial statement publishers, and plastic card processors.
Information Disclosed To Parties That Provide Services To Us
We may disclose all the information we collect, as described above, to companies that perform other services on our behalf in order for us to conduct the business of the credit union and provide our members with competitive products and services. We may also disclose nonpublic personal information about you under circumstances as permitted or required by law. These disclosures may include information to process transactions on your behalf, conduct the operations of our credit union, follow your authorized instructions, or protect the security of our financial records. We only work with companies that agree to maintain strong confidentiality protections and limit the use of information we provide. We do not permit these companies to sell the information we provide to other third parties.
Disclosure of Information About Former Members
Except as may be permitted or required by law, we will not share information we have collected about you if your membership is terminated at Integrity Federal Credit Union.
How We Protect Your Information
Protecting the privacy of our members is a commitment of Integrity Federal Credit Union. As a member you can help by following these simple guidelines:
- Your account number, plastic card numbers, PINS (personal identification numbers), or passwords need to be kept private and protected. Never keep your PIN with your card, which can provide free access to your accounts if your card is lost or stolen.
- When disclosing your account numbers, social security numbers, etc. to other persons, use caution. Beware of anyone calling you and claiming the call is for credit union business and asks for your account number. Official credit union staff will have access to your information and will not need to ask for it.
- Keep your information with us current. Inform us of any changes in your address or phone number. It is important that we have current information on how to reach you. If we detect potentially fraudulent or unauthorized activity or use of an account, we will attempt to contact you immediately.
- Let us know if you have questions. Please do not hesitate to write or call us – we are here to serve you!
971 Wooster Road, West – Barberton, Ohio 44203
Phone: (330) 825-2455 – Fax: (330) 825-4877
www.integrityfcu.org
PURPOSE
This section describes overdraft approval policies and processing requirements formalized by the Board of Directors of Integrity Federal Credit Union on April 28, 2011.
All employees of Integrity Federal Credit Union, herein referred to as the “Institution”, must comply with the terms of this policy immediately. Managers, employees and technical personnel must modify applicable system configurations and procedures, if necessary, to comply with the terms of this plan within 10 business days.
DEFINITIONS An “overdraft” is technically classified as an account in which the balance has been reduced to an amount below zero. This may occur by one of the following reasons:
- A debit presented for payment where the account does not have sufficient funds to pay the item
- A deposited item returned where the account does not have sufficient funds to absorb the charge back
- The establishment of an approved overdraft limit for a specified account group
POLICY STATEMENT Overdrafts are not an encouraged method for extending credit and, as such, should be strongly discouraged. The decision to grant an overdraft within established limits is automatic; exceptions to preassigned limit(s) should be clearly documented and approved by Senior Management.
A report of overdrawn accounts will be reviewed and monitored on a daily basis by a designated manager or overdraft coordinator.
STANDARD OVERDRAFT SERVICE The Board of Directors and Senior Management have established and approved the following standard overdraft service for all share draft accounts in good standing:
Institution will authorize and pay overdrafts up to the assigned overdraft limit for the following types of transactions, unless the member has chosen to opt-out:
- Share Drafts
- ACH transactions
- Recurring debit card transactions
Institution will NOT authorize and pay overdrafts for the following types of transactions, unless the member has chosen to opt-in:
- ATM transactions
- One-time debit card transactions
OVERDRAFT LIMITS The Board of Directors and Senior Management have established a limit of no more than $500.00 in overdraft balances per member. Exceptions to this policy will require approval by an authorized officer. Further, a cap of $500.00 in total dollar amount of all overdrafts (including fees) has been established which is consistent with the credit union’s ability to absorb losses. The credit union retains the right to return or discontinue payment of overdrafts at any time without prior notice to members.
The overdraft limit of $500.00 will be extended to all Share Draft Accounts in good standing according to the follow procedure:
- The overdraft limit will automatically be available beginning 60 days from account open date for share drafts, ACH, other debits and recurring debit card transactions unless the member has opted-out, the account is not in good standing or does not qualify based on other criteria.
- Effective August 15, 2010 for accounts opened prior to July 1, 2010 and new accounts opened on or after July 1, 2010, the member must consent or opt-in to having the overdraft limit activated for ATM and one-time debit card transactions. The member can opt-in by phone, on our website or by providing a signed opt-in agreement. Within one business day of receiving the opt-in request, the credit union will mail a written acknowledgement to the member confirming their election to opt-in and their ongoing right to revoke their opt-in status. The limit will be activated the same day the written acknowledgement is mailed.
ENFORCEMENT Changes to this policy require approval by the Board of Directors of the Institution. Changes in operating procedures, standards, guidelines and technologies, provided they are consistent with this policy and are compliant will all current financial regulations, may be authorized by an officer.
The Board of Directors has the authority to approve this policy, and annually approves the merit thereafter. Senior management is responsible for ensuring the directives are implemented and administered in compliance with the approved policy.
The primary responsibility for enforcement of this policy and its operating procedures rests with management and our employees.
No part of this policy or its supporting operating procedures should be interpreted as contravening or superseding any other legal and regulatory requirements placed upon the Institution. Protective measures should not impede other legally mandated processes such as records retention or subpoenas. Any conflicts should be submitted immediately to Senior Management for further evaluation and/or subsequent submission to the Institution’s legal counsel.
EXCEPTIONS TO POLICY Requests for exceptions to this policy must be very specific and may only be granted on specific items, rather than to entire sections. Institution personnel with exceptions are to communicate their requests by completing an internal memorandum to an officer for consideration by Senior Management.
APPROVAL PROCEDURES All Overdrafts are to be promptly reviewed by an officer before the daily deadline for returning the items which created the overdraft. An overdraft report and NSF item report will be created and initialed by the officer assigned to review and/or approve the overdrafts.
APPROVAL AUTHORITY Overdrafts that are not a result of a systematically approved overdraft limit will require approval within established credit authorities. To determine the necessary level of approval, refer to the Institution’s GENERAL LOAN POLICY for approved lending/overdraft limits.
COLLECTION OF OVERDRAFTS Collections of overdrafts will be primarily performed by mailing system generated collection letters based on consecutive days overdrawn as described below; until the overdraft is either paid or charged off:
- 15 day reminder letter
- 30 day suspension letter
- 45 day account closed and charged off
Collection efforts will also include telephone calls to the member when the account is overdrawn for 30 or more consecutive days.
Accounts that bring their balance positive between 30 and 45 days overdrawn will continue to have their overdraft limit suspended, pending approval of reinstatement by management.
Accounts overdrawn 45 consecutive days will be charged-off and reported or referred to ChexSystem.
PROGRAM REVIEW A review will be conducted by an officer, or their designee, on a periodic basis to determine not only staff compliance with this policy, but also to identify account holders who may be offered alternative means of handling their finances (i.e. – Line of Credit, Automatic Transfer from Other Account, Opt Out of the Program). This review shall be documented, along with correspondence to/from account holders resulting from the review.
OVERDRAFT AND RETURN ITEM CHARGES Overdraft and Return Item Charges shall be set at $25.00 with subsequent changes requiring prior board approval and a minimum 30 day notification to account holders prior to implementation. Refunds of these fees will require approval of an officer or supervisor after an initial “one time” courtesy refund and re-education of the consumer on the policies for overdrafts.
OVERDRAFT NOTICES TO ACCOUNT HOLDERS Account holders will be mailed at the earliest possible time a notice for each instance of overdraft or increase in overdraft. This notice will disclose the amount of the overdraft, the debit(s) which created the overdraft, the fee assessed for the overdraft and contact information should they desire to discuss the overdraft.
Additionally, a reminder notice will be mailed after 15 consecutive calendar days of overdraft. This notice shall note the date and amount of the overdraft outstanding, and remind the account holder of the time limit to resolve the overdraft.
RETENTION OF DOCUMENTATION Correspondence received from account holders, documentation of opt-ins to include any staff documentation of verbal correspondence, shall be maintained for a period of no less than three (3) years. This correspondence shall be logged and filed such that retrieval during examinations is accomplished with ease.
Retention of system generated overdraft reports shall be maintained in accordance with existing guidelines.