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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?

Yours truly
George Self

--------------------------------------------------------------------------------

George Self : Management-Assistance: Programs and Services, Inc. 
86 Sherwood Road - Asheville, NC 28803 USA - www.management-assistance.com
Office: 828-252-2651/800-544-8269 both Ext. 17 Fax: 866-422-8710 - Cell: 828-230-5802 - Home: 828-252-8029    

Last Updated 07/02/2004regs@fdic.gov

Last Updated: August 23, 2024