BANK OF IDAHO June 29, 2004 Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429 Dear Mr. Feldman: The Bank of Idaho has reviewed the newly published Interagency Guidance on Overdraft Protection Programs, published in Volume 69, Number 109 of the Federal Register on June 7, 2004. The Bank of Idaho was pleased to see that the majority of the requirements and best practices are already being followed in financial institutions utilizing the IMPACT Overdraft Privilege Service. There are a few areas which we believe are worth of comment. Charge Off Overdrafts at 30 Days: Our collection process is designed to minimize losses while focusing on customer retention. This process is designed to make systematic contact with the customers and determine which customers wish to cure their negative balance and which are deserving of being charged off. This process has been used for quite some time and we believe that it efficiently manages risk. The Bank of Idaho would advocate that overdrafts be allowed up to an aging of sixty (60) days prior to charging off an overdraft but in no event less than forty-five (45) days as credit union regulations currently require. Repayment Plans: The guidelines suggest that repayment arrangements which are formalized between a depositor and a bank should be charged off when the underlying overdraft has aged past thirty (30) days. The Bank of Idaho has experienced a high degree of success in utilizing repayment plans and find that they provide an additional safety net for the customers. These repayment arrangements also produce a small degree of risk during the period in which they are being paid according to their terms. Accordingly, the Bank of Idaho would suggest that current and performing repayment plans not be charged off. Thank you for your consideration. Jeffrey E. Jones
Executive Vice President
Bank of Idaho
151 N. Ridge, Suite 240
Idaho Falls, ID
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