FDIC Federal Register Citations

July 20, 2004

Mr. Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street Building N.W.
Washington, DC 20429

Mr. Feldman:

I would like to comment on PR 60-2004, pursuant to your request.

Farmers and Traders Bank has an overdraft program that is convenient and well liked by our customers. We have not advertised this service nor promoted it.

Customers who are overdrawn greater than ninety days with no deposit activity are charged off according to GAAP. Customers who are overdrawn ninety days, but continue to make deposits are placed in a "restart" program where a repayment scheduled is put in place to cure the overdraft without interest or fees and the overdraft protection is discontinued.

We believe that a thirty day period is too short for recognition and rehabilitation of a overdraft that has had deposit activity. This short window could cause a hardship for customers with direct deposit and debit transactions in an area where transportation can be an issue.

In conclusion, we believe that our current procedures, that allow for limited overdrafts, in a carefully controlled and monitored way offers convenience and value for our customers.

Sincerely,

William P May, President
Farmers and Traders Bank
93 Marion St.
Campton, KY 41301