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#235310 - 08/23/04 02:21 PM Overdraft Protection
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Has anyone heard any news on the Interagency Guidelines for Overdraft Protection? The comment period ended on 08/06. Thanks

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Operations Compliance
#235311 - 08/23/04 02:59 PM Re: Overdraft Protection
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
No, nothing yet. This is on a different track and time frame than most regulatory proposals:

1) there is no Congressional mandate that it be done, so there is not even a target date by which it should be completed;
2) grafting changes on to an existing regulation in the absence of a Congressional mandate is an extremely difficult task - Congress never told them to regulate overdraft protection programs and doing it under the guise of changing Regulation DD which "interprets" a statute passed several years ago requires some real drafting skills;
3)while amendments to Regulation DD are the sole responsibility of the Fed, the "best practices" proposal reflected an interagency effort and, in candor, the agencies have no skills at working with each other*; and
4) they first requested comments in November 2002, but did not come out with a proposal until June 2004, so this is not a fast track issue.

It could be by the end of the year. It could be never.

*Porcupines at least have the desire to make love. The agencies prefer not to cross pollinate.

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