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Public Comment, Stufy of Overdraft Protection Programs, America's Community Bankers

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5 pages
March 9, 2007 Mr. Steve Hanft Legal Division Federal Deposit Insurance Corporation th550 17 Street, NW Washington, DC 20429 Re: Study of Overdraft Protection Programs 72 FR 5718 (February 7, 2007) Dear Mr. Hanft: 1America's Community Bankers (ACB) appreciates the opportunity to provide comments on two draft surveys designed by the Federal Deposit Insurance Corporation (FDIC) to collect information regarding overdraft protection products offered by state nonmember financial 2institutions and the usage patterns of overdraft products among depositors in those institutions. This information will be collected in two parts: a survey questionnaire that will be distributed to 500 state-chartered nonmember financial institutions and an additional micro-data collection in which more detailed information will be collected from up to 100 of these institutions. These draft surveys have been proposed following the FDIC’s consideration of comments on earlier versions of the surveys. ACB submitted comments on the earlier drafts in a letter to the FDIC dated December 18, 2006. The supporting statement the FDIC submitted to the Office of Management and Budget (OMB) regarding the surveys indicates that the FDIC has “little systemic information about the features of overdraft protection programs and how the features are related to the usage and the attendant accrual of fees.” The FDIC states that, as a banking regulatory agency charged ...
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March 9, 2007
Mr. Steve Hanft
Legal Division
Federal Deposit Insurance Corporation
550 17
th
Street, NW
Washington, DC 20429
Re:
Study of Overdraft Protection Programs
72 FR 5718 (February 7, 2007)
Dear Mr. Hanft:
America's Community Bankers (ACB)
1
appreciates the opportunity to provide comments on two
draft surveys designed by the Federal Deposit Insurance Corporation (FDIC) to collect
information regarding overdraft protection products offered by state nonmember financial
institutions and the usage patterns of overdraft products among depositors in those institutions.
2
This information will be collected in two parts: a survey questionnaire that will be distributed to
500 state-chartered nonmember financial institutions and an additional micro-data collection in
which more detailed information will be collected from up to 100 of these institutions.
These
draft surveys have been proposed following the FDIC’s consideration of comments on earlier
versions of the surveys.
ACB submitted comments on the earlier drafts in a letter to the FDIC
dated December 18, 2006.
The supporting statement the FDIC submitted to the Office of Management and Budget (OMB)
regarding the surveys indicates that the FDIC has “little systemic information about the features
of overdraft protection programs and how the features are related to the usage and the attendant
accrual of fees.”
The FDIC states that, as a banking regulatory agency charged with monitoring
bank compliance with consumer protection laws and regulations, the agency needs more
information about overdraft protection programs and the usage of such programs in order to aid
future policy making decisions.
1
America's Community Bankers is the national trade association committed to shaping the future of banking by
being the innovative industry leader strengthening the competitive position of community banks. To learn more
about ACB, visit
www.AmericasCommunityBankers.com
.
2
72 Fed. Reg. 5718 (Feb. 7, 2007).
Survey of Overdraft Protection Programs
Survey of Overdraft Protection Programs
Survey of Overdraft Protection Programs
Survey of Overdraft Protection Programs
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