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#1121567 - 02/03/09 02:00 AM Free Checking
newbank Offline
Member
Joined: Dec 2007
Posts: 78
I have two questions for our Free checking account:
1. Free personal checking - we've been offering a free checking ever since 2005 and my CEO all of sudden wants to stop offering and assess some kind of fee. The problem is we can stop offering for future customers but what about existing ones? Without violating Reg DD, is there any way we can assess any kind of fee? Can we chagne the account type to something else where there is a monthly fee for monthly balance requirement etc., if we disclose beforehand?
2. Free business checking with 50 debits allowance- we plan to reduce 50 debits to 30 and if exceeds, charging $1.00 per debit. If we are to disclose this 30 days prior in changing, is it ok? We are located in CA. Thank you.

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Operations Compliance
#1121575 - 02/03/09 04:05 AM Re: Free Checking newbank
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You can stop referring to the account as "free," disclose the imposition of the new fee at least 30 days in advance of implementation, and make sure that all new customers get account disclosures with the fee information.

As for the business accounts, you may have a contractual provision requiring a notice period for such a change. Whether or not there is a provision, it will be wise to give customers notice. Perhaps someone from California can advise whether you have a state requirement for notice.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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