KEYSTONE BANK
July 31, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429 In re Interagency Guidance on Overdraft Protection Programs, FIL-63-2004 Dear Mr. Feldman: We respectfully set forth our comments in this matter. We bankers are continually and consistently concerned with the safety and soundness of our institutions. Though it is our general practice to charge off overdrafts with duration of 30 days, it seems inappropriate and in the nature of micromanaging to impose an arbitrary rule in this area. Banks should be relied upon with a degree of comfort by the regulators to be both reasonable and safe in determining their policies and procedures with respect to the nominal overdrafts resulting from overdraft protection programs. A substantial portion of this Interagency Guidance reiterates existing statutory and regulatory law. We sincerely believe that the mere mention that the Truth in Lending Act, Equal Credit Opportunity Act, Electronic Fund Transfer Act, and their respective regulations are relevant and must be considered, would be helpful, but the synopsis thereof set forth in this Interagency Guidance requires all of us bankers to take the additional time to read it. Our present body of statutory and regulatory law is vast indeed; you would do us a great favor by merely referring to it, as and when appropriate. We do commend the advice set forth under Best Practices. Though it seems a bit like trying to legislate ethics and morality, we have seen advertised "Free Overdraft Protection"-clearly misleading. Though the marketplace should, in theory, weed out the existence of such marketing, your, Best Practices gives appropriate guidance for both bankers and examiners in the field. Yours very truly,
Robert L. Levin
President | 
