Our bank is wanting to set up a service where if you overdraw your account, we will sweep funds from another account of yours to another so that you will not be charged an overdraft fee. However you will be charged anther fee for this service. Where do I being on creating the disclosures for this product. I know we will need to have an agreement in place with the customers authorizing us to transfer funds from one account to another. What else will I need to disclose?

Our sweep agreement form is actually a form from our loan system. I believe it's the same form as the AFT form but with different boxes checked.

there are 2 options here, one is an "overdraft" sweep from a line of credit, which is basically a loan product. Most banks charge something for this. You are talking about customer account A is OD, so you take funds from customer account B to cover account A. Since this is taking from a customer's existing account, your only disclosure should be a change in fee structure for your customers, and whatever contractual agreement you make the customer sign.

Thanks!