Overdraft Comment on letterhead[2]

June 27, 2008 Ms, Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Ave, NW Washington DC 20551 Re: Regulation AA- Unfair or Deceptive Acts or Practices and Regulation DD- Truth in Savings Office of Thrift Supervision: Docket ID OTS-2008-0004 National Credit Union Administration: RIN 3133-AD47 Federal Reserve Board: Regulation AA: R-1314 & Regulation DD: R-1315 Dear Chairman Bernanke, Members of the Board, and Board Secretary Johnson: Consumers Union of U.S., Inc, the nonprofit publisher of Consumer Reports, writes to comment on proposed Regulation AA - Unfair or Deceptive Acts or Practices [R-1314], the recent proposal to curb unfair and deceptive credit card and overdraft practices and companion proposal Regulation DD [R-1315] regarding the form and content of disclosures under the Truth in Savings Act. We appreciate the fact that the Federal Reserve Board (Board), Office of Thrift Supervision (OTS), and National Credit Union Administration (NCUA) (collectively “Agencies”) recognize that the current practices in the application of overdraft loan programs, which the proposals refer to as “overdraft services,” are unfair. However, there are changes that should be made to the proposed rules to ensure that they adequately address the abuses and unfair practices in overdraft loans. Our comment will address the positive changes proposed in Regulation AA [R-1314], ...