From: Lynnda Jenkins [mailto:ljenkins@sundownsb.com]
Sent: Tuesday, July 06, 2004 11:13 AM
To: Comments
Subject: FIL-63-2004 - Interagency Guidance on Overdraft Protection
It is unclear to me which, if any, of this guidance applies to banks
which
offer no "overdraft protection service"; in our case, overdrafts are
addressed purely on a judgmental basis by the officer servicing the account
and, if required, the officer's manager.
For instance, please clarify the direction to address losses under such
programs according to GAAP and Call Report instructions. It would seem to
me they should be handled this way regardless of whether there is a formal
overdraft protection product or simply a judgmental program in place, but
this section states that it applies to overdraft protection programs.
Lynnda Jenkins
Loan Review Officer
Sundown State Bank
