Question & Answer
Question: If we are offering debit cards to some customers, must the Regulation E disclosures for the debit cards be part of the general disclosures that we give to all customers?
Answer: They may be but don't have to be. First, as a general principle, over-disclosure is almost never a problem so if you want to be cautious, you can include the debit card disclosures in a master disclosure that you give to all customers. The only caution here would be that existence of the disclosure not confuse the customers who are not getting debit cards.
You may also tailor the disclosures to suit the specific products and services that the customer is getting. In this case, you would only provide debit card disclosures to customers that are getting a debit card.
Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 12, 10/98
First published on 10/01/1998