Are there any changes to the ex post counseling in situations when a daylight overdraft exceeds an institutions net debit cap?
Yes. The revised policy provides Reserve Banks some additional flexibility, if the daylight overdraft that caused the cap breach is fully collateralized. In such cases, the Reserve Banks may forgo ex post counseling for two incidents of fully collateralized overdrafts per two consecutive reserve-maintenance periods (four weeks). Institutions with de minimis, self-assessed, or max caps are eligible. Exempt cap institutions already have flexibility in counseling under the current policy, which will remain in effect under the revised policy. Institutions subject to a zero cap and those not eligible to incur daylight overdrafts are not entitled to this additional flexibility.
