Required disclosures for new accounts
by Mary Beth Guard and John Burnett Guru BIOS
Question: What disclosures are required in opening a new checking or savings account?
Answer: When opening a new checking account of any type (including business accounts), include a Regulation CC (Funds Availability) disclosure.
For consumer checking or savings, include Truth in Savings (Regulation DD) disclosures, and, if there’s any possibility of EFT activity, a Regulation E disclosure.
Don’t forget Regulation P disclosures for consumer accounts.
If a checking account includes an overdraft line of credit, include your Truth in Lending disclosure, too.
For business accounts that might involve passthrough FDIC insurance coverage, there is special disclosure information required by FDIC rules in 12 CFR
330.14.
The original version appeared in the September/October 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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