|
FIRST CHATHAM BANK
From: E. Foster [mailto:efoster@firstchatham.com]
Sent: Thursday, September 02, 2004 3:53 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
Consumer Protection in Sales of Insurance - One disclosure, signed at
closing, should suffice. It serves no apparent purpose for the applicant
to have to sign a disclosure at application if they are not buying
credit life insurance. If the consumer is buying credit life, then have
one disclosure to sign, at closing. It is less confusing for the
consumer and less
burdensome and costly for the bank.
Privacy of Consumer Financial Information - The requirement to mail
the bank's Privacy Policy to our customers annually, is costly,
redundant and confusing to consumers. If a bank gives the consumer the
Privacy Statement at the inception of the account relationship, and does
not change the policy, then there is no apparent need for annual
mailings. Only when the
bank's policy is changed, should a subsequent mailing be required.
Truth In Savings - Form over substance. When the Truth in Savings
disclosure says "Personal Money Market" and the monthly account
statement titles the account "Money Market" ....should this be a
violation? If a consumer has a money market account, titled in an
individual's name do you really think the consumer is going to compare
the disclosure to the
statement and be confused? The disclosure says that interest is
compounded daily and it is actually compounded monthly...yes, absolutely
a blatant violation. Cite violations that are substantive.
Regulation Z - Without a doubt, the most confusing regulation ever
written. I challenge any consumer to sit down with his or her consumer
note and calculate the APR or understand the logic behind the way fees
are treated on the Itemization of Amount financed. (Try to explain why
you add in the fee and then take it back out.) And, the Right of
Rescission is overkill. The consumer decided to take out the loan, and
thought through the pros and cons beforehand. It is insulting to force
them to second-guess themselves by not giving them the loan proceeds. I
feel certain that a bank would work with a consumer who had change of
heart within a three day, four day, one week period.
Overall, many regulations and corresponding disclosures can only be
understood by those have had extensive training in understanding them.
They are supposed to protect consumers, but end up only confusing them.
Let's give consumers some credit...you cannot legislate intelligence or
common sense, but that is what so many of these regulations try to do.
Thank you for the opportunity to express my opinion.
Eleanor D. Foster
Vice President
First Chatham Bank
P.O. Box 11167
Savannah, GA 31412
(912) 629-2902
(912) 629-2915 fax
efoster@firstchatham.com |
