From: Julie Rabin
Sent: Monday, November 26, 2007 4:34 PM
To: Comments
Subject: Garnishment Statement

In regard to the Proposed Joint Guidance to financial institutions on handling garnishment of accounts holding exempt Federal Benefit Funds (72 FR 55273-76):

The rule should require financial institutions to determine whether accounts contain electronically deposited exempt funds and provide that the institutions may not freeze these funds.  The rationale is that many Americans depend on social security and VA benefits for basic necessities such as food and medicine.  Freezing these funds, even if only temporarily, results in an undue hardship to the account holders.  No fees should be assessed on the account in connection with the attempted garnishment.

Julie E Rabin, Esq.
Rabin & Rabin Co LPA
55 Public Square, Suite 1510
Cleveland, OH  44113