The CFPB recently released initial data findings from its 15‐month (and counting) study of overdraft programs, including a few comments that suggest some rulemaking is in the offing. “Nothing in this report implies that banks and credit unions should be precluded from offering overdraft coverage,” the report stated. Moreover, the study noted progress in some areas in recent years in protecting consumers from harm. “Nonetheless, our findings with respect to the number of consumers who are incurring heavy overdraft fees or account...