I'll take a stab that someone will bite on this one. Two institutions merge, Bank A and Bank B. Bank B does promote ODP and is currently making the proper disclosures on statements, etc.
Bank A is the surviving institution and does not "promote" overdraft protection. Bank B will take on Bank A's products and will no longer "promote" the OD protection feature after merger in to Bank A.
Does Bank A have to continue to provide the additional statement disclosures to those customers of Bank B, after the completion of the merger, since Bank B was "promoting" on and after 07/01/06?
Last edited by John Burnett; 09/20/06 08:57 PM.