Skip to content
BOL Conferences
Thread Options
#738337 - 05/22/07 10:26 PM Employment-Related Account Perks
YosemiteSamIAm Offline
Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
If we give an employee a "perk" upon being hired of say, a free safety deposit box, do we have to provide them with a 30-day notice that we will begin charging a safe deposit box fee once they have left our employ?
_________________________
Sorry, did I just use my outside voice?

Return to Top
Deposits and Payments
#738513 - 05/23/07 02:06 PM Re: Employment-Related Account Perks YosemiteSamIAm
GenerousLife Offline
Diamond Poster
Joined: Feb 2002
Posts: 1,466
USA
I believe that we communicate all changes at the time of Exit. For example, we give our employees the "best" checking account type we have, but charge no fees. At the time of Exit we would offer them the option to change to a free account or keep the same account type, now with a fee.

To avoid dealing with the question of whether the employee left voluntarily or if you terminated them, you could make it a standard procedure that effective with the next statement cycle, annual renewal, etc., they will be charged a fee to continue the checking account or safe deposit rental.
_________________________
"No problem can withstand the assault of sustained thinking." ~ Voltaire
"Sustained thinking gives me a headache." ~Me

Return to Top
#739212 - 05/23/07 09:24 PM Re: Employment-Related Account Perks GenerousLife
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
If you followed the requirements of Reg DD, you could disclose up front that an event such as leaving the bank's employ, will trigger a change. ยง230.5, OSC (a)(1)3

The safest thing to do is to remind them and make new disclosures though I don't think that has to be an absolute requirement.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top

Moderator:  John Burnett