1.
Charge off overdraft at 30 days. Cooperative Bank advocates that
overdrafts be allowed up to an aging of sixty (60) days prior to
charging off an overdraft , but in no event no less than forty-five
(45) days as credit unions regulations currently require. This process
is designed to make contact with customers and determine which customers
wish to cure their negative balance and which are deserving of being
charged off. 2. Unused Commitment Reporting. Cooperative Bank sees no change in
this regulation is necessary. Reasons as follows: a) 60 days time
frame 2) immaterial amount 3) cost of retrieving information. 3. Free Account Disclosures. Cooperative Bank agrees with proposed
changes. We currently through training front line personnel and deposit
account agreements feel this requirement is met. 4. Notices Upon First and Subsequent Overdrafts. Cooperative Bank
agrees with proposed changes. We currently meet this requirement. 5. Repayment Plans. If repayment plan is not adhered to, we currently
charge off within thirty days (30). We would suggest that current
and performing repayment plans not be charged off.
