Mr Robert E Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St Building N. W.
Washington DC 20429
Dear Sir,
Based on your request for comment of PR 60-2004, on behalf of the
Hyden Citizens Bank, Inc., Hyden KY. I respectfully make the following:
• Our overdraft program has been well received by our customer base
and there have been no patterns of abuse or misuse.
• Marketing efforts have been minimal and the point of focus has been
on service opportunity and convenience for the customer.
• Hyden Citizens Bank has developed policies and protocols that have
been adhered to faithfully.
• Customers who have overdrafts over 90 days with no deposit activity
are charged off according to GAAP and collected in the normal course
of business.
• Customers who are overdrawn 90 days but continue to make deposits
are placed in a restart program where a repayment program is developed
to cure the overdraft based on the customers capacity and cash flow.
No interest or fee is charged and the overdraft priviledge is
discontinued. At conclusion of the restart program, customer is given
option of again utilizing the overdraft program, establishing an
overdraft protection line or continue to not participate. Management
reviews customers who qualify as candidates to be placed in the
restart program on a quarterly basis.
Our biggest concern is the narrow and short window of 30 days for the
recognition of charge off of overdrafts. This does not allow customers
with ACH or direct deposit activity to reconcile this issue and may not
reflect the best interest of the customer. As referred to above, our
refresh/restart program allows for rehabilitation and customers directed
options.
Overall the Hyden Citizens Bank customers appreciate and utilize our
service of allowing limited overdrafts. This has been developed without
a formal program or vendor utilized.
Additional regulation or guidelines will only place additional burden
on the bank and reduce or eliminate a well liked service for the
customers.
Respectfully Submitted,
W F Brashear II
President
Hyden Citizens Bank
P.O. Box 948
Main Street
Hyden, KY 41749
