MACON
BANK
June 4, 2004
Docket No. OP-1198
Board of Governors of the Federal Reserve System
Attention: Jennifer
J. Johnson, Secretary
20th Street and Constitution Avenue, NW
Washington, DC 20551
Gentlemen:
We have reviewed the proposed guidelines for Overdraft Protection
Programs as issued by the Office of Thrift Supervision (No. 2004-30).
For the most part, the regulation seems to be reasonable. Most of
the recommendations are common customer service issues, many of which
we already have in place and would require little or no change at
our institution.
We do recognize that the recommendation to monitor individual usage
would require some system changes and would increase the amount of
time spent in administering the program.
The recommendation
to "Consider daily limits" is
a concern to us. There is no such restriction for customer accounts
if the
withdrawal items are returned to the payee. The number of debits
which result in account overdrafts is controlled by the customer.
We do not see any reason to show partiality to the customer for whom
we are doing a service by paying the checks, when the customer who
opts out of the program will pay a fee for each and every overdraft.
Please take these comments under consideration as you plan the final
version of the guidance document.
Thank you.
Yours truly,
Brenda Brown
First Vice President/Operations
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