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#110358 - 08/27/03 06:32 PM Reg DD-Change in Fees
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
I think I'm right but I want to doublecheck. We're increasing our annual IRA fee and the IRA transfer fee (to go to another bank). We've sent out notification well in advance of the required 30 days to our IRA customers. Joe customer complains to Division of Banks that he's tied into his IRA term because there's early W/D penalties to take the money out and he doesn't like the fee increase. My point....An IRA customer enters into a specific term (18-month IRA say), can we increase the plan fees during this term as long as we've provided notice at least 30 days ahead of time? I think so but want to make sure. Thanks!

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#110359 - 08/27/03 07:39 PM Re: Reg DD-Change in Fees
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
I don't believe you can. Your IRA deposit for a specific term is a contract. Both sides have to honor the terms of that contract for as long as the contract lasts. The kicker here would be if your IRA agreement allowed changes to the terms of the agreement. My guess is that your agreement doesn't read that way. I know ours don't.

That would mean that you would have to wait to enforce those terms until the next renewal of the certificate.

THe good news: by providing the new terms now, you have met the change in terms notification on the renewal.
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#110360 - 08/27/03 07:49 PM Re: Reg DD-Change in Fees
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
The TIS disclosure they receive doesn't state the annual and transfer fees. These fees are only listed on the fee schedule that we hand them when the account is opened and the fee schedule is just a listing of fees, doesn't state we can/cannot change them and when. So...because their disclosure "contract" doesn't state specific fees can't we change them when we want with sufficient notice?

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