Public Comment, Study of Overdraft Protection Programs, Mass. Bankers Assn.

Massachusetts Bankers Association 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 Dear Mr. Hanft: On behalf of our 205 commercial, savings, cooperative banks, and savings and loan members in Massachusetts and throughout New England, the Massachusetts Bankers Association (MBA) appreciates the opportunity to comment on the Federal Deposit Insurance Corporation’s (FDIC) second notice and request for comment entitled “Study of Overdraft Protection Programs.” In the notice, the FDIC provides updated estimates of the potential burden of the data collection on respondents and again requests comments on whether the collection is necessary, ways to enhance the quality and utility of the information, and further ways to minimize the burden on respondents. MBA continues to have concerns with the FDIC’s intent to collect data on overdraft protection programs. As we stated in our first comment letter, significant regulatory changes governing these s went into effect on July 1, 2006. In addition, joint regulatory guidance containing a number of recommended “best practices” was issued approximately 18 months ago. Changing consumer habits takes time, however and we remain concerned that the FDIC will not obtain an accurate assessment of how the new rules are working. We would recommend waiting at least 12-18 months so that the new ...