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FDIC Federal Register Citations


PRIORITY ONE BANK 

From: Odean Busby [mailto:obusby@priorityonebank.com]
Sent: Wednesday, July 14, 2004 5:30 PM
To: Comments
Subject: Interagency Guidance on Overdraft Protection Programs

Robert E. Feldman, Executive Secretary
Attention Comments
Federal Deposit Insurance Corporation
550 17th Street, N. W.
Washington, D. C. 20429

Re: Overdraft Privilege Programs

Dear Mr. Feldman:

Our bank has been offering overdraft protection for as long as we have been a bank and it has always been done on an informal basis with limits set per account internally. Approximately three years ago we implemented an automated overdraft privilege program after much research with the regulators and legal counsel. We made every effort to implement this in a way that was a benefit to our customers who met certain activity criteria and proved themselves worthy of having an overdraft privilege limit. All the proper communications and disclosures were provided to our customers as to how the program would be administered.

I can say that it has been extremely well received by our customers as a service that they have seen in a very positive way. It has worked well for our customers as a much needed service for them and it has improved income for the bank.

I would encourage you to offer guidance in the form of best practices for this product and not to strap everyone with even more regulation that may in itself destroy the real usefulness of this program for our customers. Most if not all of the concerns that you have outlined in the letter seeking comment has not been an issue in our program. We have used the Strunk & Associates, L.P. program since the inception.

We encourage you and other regulatory agencies not to overreact to something that has clearly been well accepted by our customer base and has in many cases actually saved the customer money and embarrassment of having returned NSF checks.

Sincerely,

Odean Busby
Chairman & CEO
PriorityOne Bank
Magee, MS


Last Updated 07/16/2004 regs@fdic.gov

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