Robert E. Feldman, Executive Secretary
Attention: Comments/Executive Secretary Section
Federal Deposit Corporation
550 17th Street, NW.
Washington, DC 20429
Re: Federal Deposit Insurance Corporation's Interagency Guidance on
Overdraft Protection Programs
Dear Sir:
I would like to thank you for the opportunity to comment on the
Interagency Guidance on Overdraft Protection Program.
"Overdraft balances should generally be charged off within 30 days
from the date first overdrawn."
Our bank feels that a better time frame for charging off overdraft
balances would be within 60 days from the date first overdrawn. It has
been our experience over the years that most customers will cover their
overdraft balance within 45 to 60 days. Generally the charging off of an
account will be followed by the reporting of negative information to a
credit bureau. Allowing customers 60 days to cover their overdraft
balance would benefit customers better than reporting a charged
off account in their credit report that would be harmful to their credit
history. This would also allow the bank time to work with customers
experiencing short term financial problems.
Respectfully yours,
Vicki H. Morton
Compliance Officer
West Alabama Bank & Trust
Marion, AL 36756
