FDIC Federal Register Citations

FIRST BANK OF TENNESSEE

From: Robin Brown [mailto:rbrown@firstbanktn.com]
Sent: Friday, July 16, 2004 2:30 PM
To: regs.comments@occ.treas.gov; Comments
Subject: OVERDRAFT PROTECTION GUI8DANCE

To Whom It May Concern:

I am writing in reference to the proposed changes to Reg DD. I do not agree
with what the regulators have proposed about charging off accounts. I have
found at my bank that the longer a customer is allowed to remain at a
negative balance the more likely they will continue to get further in debt
to the bank. Our overdraft program is monitored daily and our customers
receive notices when their account is at a negative balance. Most of them
try to take care of it promptly but the others usually do not make any
attempt.

We do take into consideration all of our customers that get paid bi-weekly
and monthly. We have let some of our customers run with a negative balance
for 45-60 days. Consequently, we have found that the fees continue to grow
due to the fact that the customers continue to use their atm/debit cards and
write checks.

I feel that the sooner a negative account is closed, the lesser the bank’s
loss will be. The 30-35 days gives sufficient time for all customers to at
least make arrangements to get in good standing with the bank.

Sincerely,

Robin Brown
Customer Service Representative
First Bank of Tennessee