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FDIC: Study of Overdraft Protection Programs

ABA Contact: Nessa Feddis
Published: 71 Federal Register 47224
Comments Due: October 16, 2006
Disposition: Filed

Summary

In a comment on the FDIC's proposed overdraft protection survey and data download, ABA observes that "given the recognized value of overdraft protection programs and the absence of any material unsafe or unsound conduct with respect to their delivery, ABA believes that the proposed survey is untimely, unduly burdensome and unnecessary for any reasonable supervisory purpose."  ABA proposes meeting with the FDIC "to explore what means and methods may exist to achieve the legitimate supervisory interests of the agency—be that through an improved survey, a narrow data collection or other more effective means."

2006 Regulatory Chart
ABA Comment Letter
Federal Register