Our berm was made by building up and compacting the soil [clay dirt] from the dig. We compacted the sides as best we could and leveled everything [used a water level system]. But soon after it was filled, we had some big, big rains over a couple of weeks time. We found one spot where the edge was lower and the pond was overflowing there [it wasn't where I'd put the drain], into a place in the yard that already has poor drainage -- the edge was high enough to keep the yard water out, but not to keep the pond water in. Just this past week was able to pull the liner back and build that edge up. What I think had happened was this was my walk-in entry point, and I was further compacting the edge whenever I got into the pond.
If you make a berm, also be sure it's the same size [depth, width, whatever] all around as well as the same height. And if it is a soil berm, consider making it higher than you would think, because the soil will continue to compact.