FDIC Federal Register Citations

Bank of Old Monroe

From: Dale McDonald
Sent: Wednesday, July 28, 2004 5:16 PM
To: Comments
Subject: Overdraft Proposed Guidelines

We, the Bank of Old Monroe, have reviewed the newly published Interagency Guidance on Overdraft Protection Program, published in Volume 69, Number 109 of the Federal Register on June 7, 2004.

Although we agree with most of the proposals, we do have a few concerns.

First, the proposal indicates charging off accounts at 30 days. We feel 30 days is an unrealistic expectation for consumer repayment. A majority of our customers are genuinely concerned about repaying their debt, but it often requires a time period of 60 days. Allowing only 30 days for repayment and then charging off the account will have a negative impact on customer relationships. In addition, the financial risk for carrying such debt as a performing asset for an additional 30 days should not have a significant financial impact on the Bank. At a minimum, the Bank would request 45 days to charge off an overdraft, as credit union regulations currently require.

Second, the proposal suggest that notices be provided containing certain specific information upon the occurrence of the first overdraft paid under the service as well as later uses of the privilege. The Bank has historically sent out notices promptly upon an overdraft being created, however our current system does not accommodate inclusion of the proposed additional information.

It is our hope that the agency careful consider our comments. We wish to continue to provide the Overdraft Protection Program as it continues to be a needed resource for our customers and profit center for our Bank.

Sincerely,
Dale McDonald
Vice President
Bank of Old Monroe
P O Box 188
Old Monroe, MO 63369