It is a regrettable fact that predators emerge in the wake of disaster.  It is also worth noting that a truly debilitating disaster, like Katrina, can turn the ordinary into the predatory.

Accordingly, the Federal Reserve and other regulators have issued a bulletin encouraging banks to "assist victims of Katrina."  Such assistance may include: not charging fees on ATM transactions, waiving overdraft fees as a result of paycheck interruption, allowing loan customers to skip or defer some payments, and waiving late fees on credit card or other loan balances.

While many banks, including BofA, JPMorgan Chase, and Washington Mutual, have implemented some of the Fed's recommendations, a more uniform and mandatory policy may be worthwhile.

1.  The Fed guidance is very broad, and the banks are able to set for themselves the level of assistance.  Uniformity is desireable to ensure that some victims of Katrina do not find themselves in dire straits just because their bank decided not to implement certain of the Fed's recommendations. 

2.  While national banks may be more financially able to do more for their customers (and face more complaint from customers not affected by Katrina if they don't), smaller local institutions may not.  Some will use the opportunity to be predators.  Others will just not be financially able to offer concessions, especially if they are located entirely within devastated areas.  Regulators should address this problem, perhaps by making smaller institutions whole for any concessions they give.

3.  Banks, in general, wait for customers to call and request these forms of relief.  The relief is not automatic.  So, a customer who doesn't call in to request relief may end up paying those late fees.  At a minimum, regulators could require banks to automatically implement their Katrina relief program for any customers living in declared disaster areas.

Katrina's victims need long-term solutions to their sudden homelessness and unemployment.  A more considered framework for assisting them seems appropriate given the extent of the devastation.  Just as the pending bankruptcy legislation needs to be revisited in light of Katrina, there are small (and perhaps more easily accomplished) actions that will hep prevent the ordinary from becoming predatory.