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
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