I know if we change terms to an account we have to do a change of terms notification, however, if we change a non-account related service charge (i.e. telephone transfer charge), are we required to send a change in terms notice? Thanks!

You can't notify nonaccountholders in advance so there is no notice requirement. But I'm confused how you transfer funds for someone not having a deposit with you?

I don't think you can treat a telephone transfer charge as a non-account related service charge. Non-account related charges are charges for services that are provided both to depositors and non-depositors. For example, charges for money order or cashier's check purchases.

Oh, I didn't word my question correctly. Sorry about that. I should have said non-account specific charge. So, this fee change for telephone transfers would apply to all deposit accounts.

And the change is something you need to notify the holders of those accounts about under Regulation E if the transfers are considered EFTs (some are; some aren't). Reg E allows you to make the notification 21 or more calendar days prior to implementing the increased fee.

Thank you. I took a look at reg E and found the section you were referring to. It looks like we do need to send a notice.

I was corrected by a co-worker. The change in fee is for non-automated telephone transfers, so I don't think Reg E applies. This scenario is when a customer calls the bank and requests a funds transfer between accounts. Customer service will either prepare paper tickets or do a keyboard transfer. Currently, we do not charge for this service, but plan to start charging. Does this fall under Reg DD Section 230.5 Subsequent disclosures as an 'adverse affect on the consumer' requiring a 30 day advance notice?

Regardless of whether it is covered under Regulation E, this is a fee required to be disclosed under 1030.4(b)(4) and requires a 30 day notice.

Thank you.

If it's a charge that's disclosed under Reg DD and not Reg E, there's a 30-day notice. If it's under Reg E and not Reg DD, it's a 21 day notice. If both, Reg DD allows you to use the Reg E notice period.