Post August 15 Reg E Strategy Provides Opportunity

For the past several months, every bank I visit has been working tirelessly to educate and encourage customers to opt-in for OD coverage in response to Reg E. Multi-channel communications, including direct mail, email, outbound phone, statement inserts, online banners and in-branch literature have all been focused on helping customers understand the potential impact of the regulation while hopefully limiting the lost fee revenue associated with the regulation.

While the regulation took effect on July 1 for new customers opening accounts, banks realize that the real impact will be felt after August 15, when transactions are denied and overdraft fees can no longer be collected from current customers who have not opted-in. So what are your post August 15 strategies for customers who have not opted-in?

First of all, realize that despite your best efforts to reach out to customers using all available channels, the majority of customers at your bank who have not opted-in will not understand the real life impact of a denied transaction at an ATM or merchant until it occurs. This will lead to a noticeable increase in customer complaints that will require proactive communication and the preparation of all customer facing employees.

When a transaction is declined, speed of follow-up communication will be key. If you have a valid email address of the customer impacted, it is best to use this channel to explain why the denial occurred and how it can be avoided in the future. An electronic link to your opt-in jump page will be a requisite. In addition, many banks will be reaching out to the impacted household with a phone call and even a letter with an opt-in form (or link) included. Other options to cover overdrafts should be communicated through these channels as well.

All front line employees also need to be prepared for irate customers who have had transactions denied. This preparation should at a minimum include:

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  A reinforcement of the basics of Regulation E
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  A series of anticipated complaints and questions that they will confront
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  Samples of all customer communications that were used during your opt-in campaign
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  Tools to facilitate the opting-in of the customer

In communicating with a complaining customer, it would be helpful if employees have access to approximate dates the customer may have received the communication and whether the customer opted-out (or if there was simply no response to the communication). There should also be additional FAQ brochures available to assist the customer in either changing their opt-in status or better understanding the impact of opting-out.

A customer who has a transaction denied poses a significant threat of attrition to your bank. Alternatively, this customer also provides a great opportunity to more fully explain that the regulation is universal with all banks and that there are alternatives going forward. This full disclosure can result in a 'saved' customer as well as significant retained fee income or even a cross-sell opportunity.

I would love to hear from you regarding your bank's post August 15 communication strategy. Are you going to use multiple channels to communicate? Is any bank going to have a strategy for households that reach a low balance threshold other than an overdraft?