Recently, NCUA Board Member Debbie Matz, speaking to a meetingof the American Association of Credit Union Leagues, cautionedagainst offering "bounce protection programs through third partieswhich charge very high fees." It has been my experience, as counselfor a large provider of these services, that the fees charged forbounce protection are set by the credit union and not the vendor.The member suffers no disadvantage regardless of whether theoverdraft program was created and administered "in house" orthrough a vendor. The overdraft fees are, in fact, the same as thecredit union's fees for returning checks unpaid in order tomaintain their exemption under Regulation Z, and meet other legalrequirements. Richard S. Schulman Attorney Northampton, Mass.(Editor's Note: Schulman offers legal services to overdraftprotection firm BancServices Group, which is marketed to CUs byAllied Solutions.)

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