Mr. Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Mr. Feldman:
I would appreciate your consideration of my comments regarding your
guidelines on "Overdraft Protection Programs":
1. Preferably 60 days, but in no event less that 45 days aging should be
allowed before overdraft must be charged off.
2. Reporting as proposed on unused commitments would greatly overstate
the risk associated with this product.
3. I would advocate allowing free account advertising with overdraft
protection when conspicuous disclaimers are included in the communication
that makes it clear that other restrictions or other fees may apply.
4. I would suggest that your proposed regulation requiring notices providing
specific information on the first overdraft as well as later uses be
deleted. Many systems do not accommodate inclusion of the type information
suggested by the guidelines.
5. I would suggest that current and performing repayment plans should not
be required to be charged off even though the underlying overdraft may have
aged passed 30 days.
Thank you for your consideration.
Sincerely,
Don Pattillo
President and CEO
Farmers & Merchants Bank
P.O. Box 1010
708 South Main Street
Stuttgart, AR