From: Stacie S. Brendle
Sent: Tuesday, July 27, 2004 9:53 AM
To: Comments
Subject: Overdraft Protection Guidance
S&T Bank
appreciates the opportunity to comment on the proposed
Interagency Guidance on Overdraft Protection Programs issued by the
federal financial institutions supervisory agencies.
We have several comments regarding the proposed guidance:
FREEACCOUNT DISCLOSURES: We would advocate allowing free
account advertising with overdraft protection programs. ‘Free’
accounts have always included fees that may be charged to the
account under certain circumstances. These fee amounts and the
circumstances under which they may be charged are detailed in the
depository agreement in accordance with Regulation DD. Providing
clear and conspicuous notification of the fees and restrictions of an
overdraft protection program allows the consumer to make an
informed decision of the benefits of this service.
CHECKCLEARING POLICIES: We would respectfully submit that
the ability to state the structure of payment order of all possible
debits to an account in a clear and concise manner for the average
consumer is nearly impossible. It is an exceedingly complex process
due to the many and varied types of possible debits available.
Disclosing this process would be lengthy, cumbersome and
confusing to the consumer.
PROVIDEELECTION OR OPT OUT OF SERVICE: We would argue
that allowing a customer to opt out of an overdraft protection
program is unnecessary due to the fact that customers that do not
overdraw their deposit account are making an implicit decision to
not participate in the program. Customers that do overdraw their
accounts are able to save substantial additional charges that may be
charged by merchants when checks are returned and avoid the
embarrassment caused by a returned item.
S&T Bank
appreciates the chance to respond to the proposal. Please
accept our comments and consider them in your deliberations of the
final
guidance. Thank you for your time.
Stacie Brendle
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