FDIC Federal Register Citations

The First National Bank of Canadian

From: First National Bank Canadian [mailto:fnbc@classicnet.net]
Sent: Tuesday, July 27, 2004 3:25 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov; Comments
Subject: Comments

Re: Docket No. R-1197-Truth-In-Savings Act

Dear Sirs:

The First National Bank of Canadian is a very traditional small community bank. Like all the banks in this part of the country, we offer overdraft protection. We have both an automated program and a more traditional informal case by case discretionary coverage for “inadvertent” or “occasional” overdrafts. Our account disclosures are very clear that the bank has total discretion to pay or not to pay and that privileges can be terminated at any time.

Section 230.6 Periodic Statement Disclosures
(A)(3)(ii) Our data processing system does not have the capability to provide this new disclosure. The cost of these changes and the new disclosures will be passed along to the consumer with no additional value and certainly no better understanding of our policy.

Section 230.8 Advertising
We are already providing most of these disclosures under Truth-In-Savings including fees for the payment and/or non-payment of checks. Circumstances under which we might not pay checks can change daily. Drafting language that would cover every situation will be a daunting task and probably be totally confusing to the few consumers that might read it.

These proposed amendments would provide little or no useful benefit to our customers. This will just be another regulation that will cost banks money and consumers money.

Respectfully,

George Briant
President
The First National Bank of Canadian
Canadian, Texas