The FDIC issued its final guidance on the risks associated with automated overdraft payment programs. The FDIC received more than 900 written comments on the proposed guidance from financial institutions, their industry trade groups, individual consumers, consumer advocacy and public interest groups, and one member of Congress. The guidance focuses on automated overdraft programs, and encourages banks to offer less costly alternatives if, for example, a borrower overdraws his or her account on more than six occasions where a fee is charged in a rolling 12-month period. To avoid reputational and other risks, the FDIC expects institutions to establish appropriate daily limits on customer costs, and ensure that transactions are not processed in a manner designed to maximize the costs to consumers, such as by processing checks from the largest to the smallest. In order to give institutions sufficient time to review, consider, and respond to the expectations set out in the final guidance, the FDIC expects any additional efforts to mitigate risks to be in place by July 1, 2011.