Our new account customers are advised that OD privilege is now made available to them 30-60 days after the account is open. At that time all the OD policy and disclosures are given.

Our dear, dear tellers have taken our preprinted fee schedule provided at new account opening and added a label depicting the amount of the overdraft privilege fee-no other OD conditions are provided in writing at that time. And this fee schedule is given to all new account holders regardless of whether they have asked about OD or not.

They can't "compliantly" do this can they without giving all disclosures?

Perhaps your dear, dear management could review all of the material supplied to your branches and make sure everything stocked is acceptable and current. A list could be available for what material is to be given with specific accounts.

All disclosures are in a nice (very expensive to produce) disclosure except for the fee list, which is a (matching) preprinted flyer. They have added their own ugly little white label on their own. And FWIW-it's not a branch. It's the main office. Our branches are actually pretty good at not doing crazy things on their own. But besides all the cosmetics-isn't full overdraft disclosure required if its "advertised" in print and wouldn't this be considered "in print".

A Fee List is just that...a liting of all fees you may charge for all of your Savings/Checking related products, whether or not the custonmer is utilizing the services or not.

Would it not be possible that your customers who do have your OD service and may have utilized it are curiuos about the costs of it from time to time, and it is because they ask about the current cost of the service, that this branch has gone ahead and listed it on the fee schedule? Have you asked the branch why they are doing this?

Also, as a side note...this site is not just for bank management/compliance oficials....there are many levels of bankers, from tellers on up, who utilize this site to ask questions, and to learn more about the industry they are entering. Without tellers. LO's and other front line staff, there would be no reason for the rest of us to have jobs my dear, dear friend.

FWIW-I was not picking on tellers. I absolutely know that tellers are the face of our bank and respect them all for all they do every day of the week, having been one myself! And before it is said-I have not forgotten from where I came!

But sometimes, people, dear, dear people, myself included, do things and you have to smile and wonder why.

They are doing it so they remember to talk about the OD with new customers. MY QUESTION is . . .doesn't this trigger additional disclosures?