CUNA Regulatory Comment Call

March 1, 2010

Proposed Clarifications to Overdraft Protection Rules Under Regulations E and DD

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, 6th Floor, Washington, DC 20004. You may also contact us if you would like a copy of the proposed clarifications or you may access them here:

Regulation E clarifications
Regulation DD clarifications

QUESTIONS TO CONSIDER REGARDING THE REGULATION E AND DD CLARIFICATIONS

  1. Do you agree with the clarifications? What other clarifications should have been included?
















  2. The Fed has requested comment as to whether 90 days will be sufficient to comply with the requirement to use the term “Total Overdraft Fees” on periodic statements, especially for institutions that have been using a different term. Do you agree that 90 days is sufficient time? If not, what would be a sufficient time?
















  3. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com