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FIRST CITIZENS STATE BANK 

From: Ken Knuteson [mailto:KKnuteson@firstcitizensww.com] 
Sent: Monday, June 21, 2004 3:17 PM
To: Comments
Subject: FDIC: RIN 3064-AC77

 

REF: Interagency Guidance on Overdraft Protection:

Guidance: "overdraft balances generally should be charged-off within 30 days from the date first overdrawn."

Response: I recommend that the guidance be changed to 90 days and allow the institution to set a shorter time period if desired.

Reasoning: 1.) Many people only get paid semi-monthly or monthly and if they encounter a decrease in their pay do to sickness or a temporary layoff (rain in the construction trades), it might take a couple of paychecks to cover the overdraft.

2.) Charging-off the account is usually followed by reporting to a service of the charge-off, which could make it difficult for the person to get another account in the future. Therefore, the 30 days may not be enough time for the customer to avoid this problem.

Sincerely,

 

Ken G. Knuteson 
First Citizens State Bank 
207 W. Main St 
Whitewater WI 53190 
  

Last Updated 06/24/2004regs@fdic.gov

Last Updated: August 23, 2024