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Surrey Bank and Trust
From: Brenda Harding
Sent: Friday, August 06, 2004 4:57 PM
To: Comments
Cc: lritter@impactfinancial.com
Subject: Interagency Guidance on Overdraft Protection Programs. Proposed
Guidance with Request for Comment
Surrey Bank and Trust after reviewing the newly published Interagency
Grudance on Overdraft Protection Programs, published in Volume 69,
Number 109 of the Federal Register, as the following comments to
make:
1.CHARGE OFF OVERDRAFTS AT 30 DAYS:
Surrey Bank and Trust advocates that overdrafts be allowed up to
an
aging of sixty (60) days prior to charging off an overdraft but in
no
event less than forty-five (45) days, the same as credit union
regulations.
2. UNUSED COMMITMENT REPORTING:
Surrey Bank and Trust advocates that loss reserves be maintained
by
financial institutions and that these be based on the historical
performance of the overdraft protection service.
3. NOTICES UPON FIRST AND SUBSEQUENT OVERDRAFTS:
Surrey Bank and Trust currently sends first and subsequent overdraft
notices to customers using this product.
4. REPAYMENT PLANS:
Surrey Bank and Trust would request that current and performing
repayment plans not be charged off, as these plans produce a small
degree of risk during the period of repayment.
Brenda J. Harding
Debbie M. Neal
Surrey Bank and Trust
199 N. Renfro Street
Mount Airy, NC 27030
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