We would like to combine our dda and savings statements, but I am having a hard time finding specific guidance to get me started. We want to combine accounts where the name(s), tax reporting owner, and addresses are the same. Are we required to get the customer's signature to combine their statements, or allow them to 'opt-out' if they want to? Would this be considered a change in terms where we would need to provide 30 days advance notice? And are we able to combine other types of accounts as well, such as HSAs or MMDAs? Any help you can give me would be greatly appreciated!

We offer this service for our deposit accounts (checking,savings, CD's, IRA's, MMDA's). We require the customer to tell us which accounts they would like combined and sign the form.
As long as your provider/software allows, you may combine any accounts, however, write a policy that specifies the guidelines.

The only official direction I know of comes from the commentary to Regulation DD:

3. Combined statements. Institutions may provide information about an account (such as an MMDA) on the periodic statement for another account (such as a NOW account) without triggering the disclosures required by this section, as long as:

i. The information is limited to the account number, the type of account, or balance information, and

ii. The institution also provides a periodic statement complying with this section for each account.



You are not required to disclose whether or not you used a combined statement so you are not required to provide advance disclosure of a change. You are not required to allow a customer to opt out nor would I, but I would respond to customer requests for limiting the accounts included if it was possible. Noting the restrictions above, you may combine different types of accounts; e.g. DDA, MMDA, time deposits, IRAs, HSA's etc.

This is a good question for a post. It's not a purely legal question and your peers, like EddieT, can give you some good insight if they take the time to do so.