West Texas State Bank I am submitting comments on behalf of West Texas State Bank located in Odessa, Texas FDIC# 15466. Customer Opt-out: Since we do not take applications of any sort on our overdraft protection plan nor do we advertise it in any way, we feel that the customers that do not overdraft their accounts are making the implicit decision not to participate in the program; therefore not needing an opt-out feature. In short, keeping up with which customer opted-out and which customer did not opt-out, will be too cumbersome and unnecessary. Reporting unused portions as Unfunded Commitments: With a consumer base of roughly 7000, at a level overdraft protection of $500.00/per customer (assuming no customer had more than one account and that none were in the overdraft), we would be looking at 3.5 million in unfunded commitments on Overdraft Protection only. On the Call report it would reflect more unfunded commitments then we truly have and our liquidity ratio would be largely understated. Notifications: From what we read in the FIL-63-2004, the notification is going to be the initial disclosure we give all our customers when they open an account. This month alone, we look to have about 2200 items in the negative. With assuming one customer had an average of two items, we would be looking at sending out 1100 customized notifications. At this time, our bank does send out notices that identify the transaction, disclose the overdraft amount, and any fee associated with the overdraft. Reporting Overdraft Losses against Allowance for Loan Loss: Because our customers are not asked to pass a credit check to participate in the Overdraft Protection Program, we feel that first of all, this is not a loan and secondly, that the charging off of this amount is going to show our bank’s charge off amount more (in dollar figures) than what was actually charged off (in actual loans). Thank you for the opportunity to give our input on these types of matters and I hope that they go to the benefit of making these types of proposed regulations easier to implement in our day-to-day functions. Gorge Salinas |
| Last Updated 06/24/2004 | regs@fdic.gov |