FARMERS & MERCHANTS BANK June 28, 2004 Mr. Robert E. Feldman, Executive Secretary Dear Mr. Feldman: I would appreciate your consideration of my comments regarding your guidelines on "Overdraft Protection Programs": 1. Preferably 60 days, but in no event less that 45 days aging should be allowed before overdraft must be charged off. 2. Reporting as proposed on unused commitments would greatly overstate the risk associated with this product. 3. I would advocate allowing free account advertising with overdraft protection when conspicuous disclaimers are included in the communication that makes it clear that other restrictions or other fees may apply. 4. I would suggest that your proposed regulation requiring notices providing specific information on the first overdraft as well as later uses be deleted. Many systems do not accommodate inclusion of the type information suggested by the guidelines. 5. I would suggest that current and performing repayment plans should not be required to be charged off even though the underlying overdraft may have aged passed 30 days. Thank you for your consideration. Sincerely, Don Pattillo |
| Last Updated 07/12/2004 | regs@fdic.gov |