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FDIC Federal Register Citations From: Steve Hicks [mailto:STEVEH@mwofg.com] Sent: Tuesday, October 30, 2007 6:35 PM To: Comments Subject: Garnishment Statement The entire exemption of these federal benefits from garnishment and claims from judgement creditor's needs to be reviewed. The code states "As a result, when financial institutions receive garnishment orders and place freezes on accounts containing exempt federal benefit funds, the recipients of these funds can face significant hardship." Isn't that what a garnishment and judgement are designed to do? Do the interagencies not think that a garnishment or judgement on an individual earning a wage would not generate a hardship for them as well? It does. The code basically gives an individual who is receiving these federal benefits a green light not to pay creditor's since they know they are "judgement proof". In exchange, creditor's are probably more conservative in lending to individual's receiving federal benefits when advancing credit due to the lack of secondary repayment sources. This creates discrimination in lending practices, thus, harming the same individuals the interagencies are trying to protect. More specifically the ones on federal benefits who always pay their bills. We are all expected to repay our debts no matter what the source of income. Financial institutions are expected to analyze credit based on "fair lending" without discrimination. Why put federal benefits on a pedestal? The answer is easy; Recind the code in its entirety. |
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Last Updated 10/31/2007 | Regs@fdic.gov |