Comment on AN67-Interim Final Rule-Turner, Johannah

The years of agency, legislative, financial institution, and consumer advocate effort that went into this rule-making notwithstanding, I fear that the *result* will be to deprive significant numbers of people any access to any of their retirement benefits. While the rule sets forth workable procedures for banks to ascertain the legally protected amount and to respond to garnishment orders appropriately, it also explicitly clarifies that banks are at liberty simply to close accounts against which a single attempt has been made by a creditor to garnish protected funds! Banks have already threatened to rid themselves of this unprofitable "population" and some may well use the prohibition against charging garnishment processing fees as an excuse to carry out that threat. NOTE: Social Security Administration no longer issues paper checks. Retirement benefits must be electronically deposited into bank accounts. Retirees who live on Social Security and whose benefits are legally protected from garnishment are--according to this rule--subject to having their accounts closed and left without any means of receiving the benefit payments. If this Interim Final Rule is not modified, the effect may well be that I and many others will have our accounts closed and thus be deprived of access to our retirement benefits and made homeless/destitute. Please, anticipate and prevent this human disaster either by reconsidering your prohibition against banks charging fees to process garnishment orders or by forbidding banks to close accounts in anticipation of receving future garnishment orders. I understand the logic behind the fee prohibition, but those of us who rely solely on Social Security retirement benefits and may be subject to attempts by creditors to garnish accounts containing only protected benefits would much rather pay the bank a garnishment-processing fee (just as we pay other account fees) than have our accounts closed and our pensions made inaccessible.