FDIC Federal Register Citations

WEST ALABAMA BANK & TRUST

July 7, 2004

Robert E. Feldman, Executive Secretary
Attention: Comments/Executive Secretary Section
Federal Deposit Corporation
550 17th Street, NW.
Washington, DC 20429

Re: Federal Deposit Insurance Corporation's Interagency Guidance on Overdraft Protection Programs

Dear Sir:

I would like to thank you for the opportunity to comment on the Interagency Guidance on Overdraft Protection Program.

"Overdraft balances should generally be charged off within 30 days from the date first overdrawn."

Our bank feels that a better time frame for charging off overdraft balances would be within 60 days from the date first overdrawn. It has been our experience over the years that most customers will cover their overdraft balance within 45 to 60 days. Generally the charging off of an account will be followed by the reporting of negative information to a credit bureau. Allowing customers 60 days to cover their overdraft balance would benefit customers better than reporting a charged off account in their credit report that would be harmful to their credit history. This would also allow the bank time to work with customers experiencing short term financial problems.

Respectfully yours,

Vicki H. Morton
Compliance Officer
West Alabama Bank & Trust
Marion, AL 36756