From: Ken Knuteson [mailto:KKnuteson@firstcitizensww.com]
Sent: Monday, June 21, 2004 3:17 PM
To: Comments
Subject: FDIC: RIN 3064-AC77
REF: Interagency Guidance on Overdraft Protection:
Guidance: "overdraft balances generally should be charged-off within
30 days from the date first overdrawn."
Response: I recommend that the guidance be changed to 90 days and
allow the institution to set a shorter time period if desired.
Reasoning: 1.) Many people only get paid semi-monthly or monthly and
if they encounter a decrease in their pay do to sickness or a temporary
layoff (rain in the construction trades), it might take a couple of
paychecks to cover the overdraft.
2.) Charging-off the account is usually followed by reporting to a
service of the charge-off, which could make it difficult for the person
to get another account in the future. Therefore, the 30 days may not be
enough time for the customer to avoid this problem.
Sincerely,
Ken G. Knuteson
First Citizens State Bank
207 W. Main St
Whitewater WI 53190