Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#101845 - 07/29/03 10:44 PM new account disclousures
Anonymous
Unregistered

we are in the process of updating our new account disclosures. There will be some major changes in the way interest is paid as well as other major changes. Do we have to send a copy of the new disclosure to all existing account holders. This could be very expensive!

Return to Top
Operations Compliance
#101846 - 07/29/03 11:15 PM Re: new account disclousures
starfish Offline
Gold Star
starfish
Joined: Jun 2003
Posts: 416
Seattle
It depends on the changes you are making. Reg DD states that if you change any disclosed term which may reduce the APY or adversely affect the consumer, a change in terms notice must be mailed or delivered to the consumer at least 30 calendar days before the effective date of the change. The notice is not required for changes in the interest rate or APY on variable rate accounts; changes in fees for check printing; or to changes in any term for time accounts with maturities of one month or less.

Return to Top
#101847 - 07/30/03 01:40 PM Re: new account disclousures
LoisLane Offline
Diamond Poster
LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
Instead of mailing out the entire revised disclosures I believe you can mail a smaller disclosure that shows only the changes that have been made. You would then add a statement that all other provisions not amended remain in effect.
_________________________
And where is Superman when I need him?

Return to Top
#101848 - 07/30/03 02:03 PM Re: new account disclosures
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
And if you opt to send a complete new schedule, the changes should be identified in some way such as being hi-lited.

Yes, changes can be expensive and time consuming. Remember too that if these changes qualify for redisclosure, you will also be double disclosing to new accounts the existing and the new rules during that interim period.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top

Moderator:  Andy_Z, John Burnett