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#1116042 - 01/23/09 04:38 PM ODP disclosure
Frank Offline
100 Club
Joined: Jun 2007
Posts: 133
Central Arkansas
We have a bounce protection program that kicks in after 60 days.

We have a promotional brochure that spells out the program per 230.11 (b)(1) requirements. This brochure is handed to customer at account opening along with all other regulatory required disclosures applicable


A sr. management official saw that one branch wasn't handing out the bounce protection brochure at account opening and went ballistic claiming that it is a requirement for the brochure to given to the customer at account opening.

Here's my question. All that the 230.11 b disclosure requirements mean is that they should be included in any brochure we hand out....it doesn't mean it's a requirement for this particular brochure to be given to the customer....right?

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#1116066 - 01/23/09 04:47 PM Re: ODP disclosure Frank
Georgia Plum
Unregistered

If you have an ODP program, you must disclose per 230.11 (b)(1). As for 'this particular brochure' be given to the customer, I would contend that your policy might determine this. But if 'this particular brochure' is the only place you are making the required disclosure, then why wouldn't you give it out? I concur with your Sr. Management.

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