From: gself [mailto:gself@management-assistance.com]
Sent: Thursday, July 01, 2004 2:04 PM
To: Comments
Subject: Overdraft Protection Program Proposed Guidance
Gentlemen:
My suggestion is to do nothing.
There is no demonstrated harm that can be avoided by new regulation. Many
consumers report satisfaction with the program as it now stands. The program
fulfills a legitimate consumer need at a reasonable price. Any abuses do not
appear to be widespread or “systemic”. Existing regulation of NSF items is
sufficiently provided under Reg Z. It seems to me that regulators can deal
with isolated abuses on a case-by-case basis. After reviewing the "Best
Practice" suggestions, it appears to me that most are already being done, to
the extent that DP processes permit. Before any new procedures are
implemented, why not perform a "needs assessment" to quantify whether or not
a real need exists?
