Some time back our bank created sub-accounts in our demand deposit and NOW accounts in order reduce reserve requirements. Language was inserted in our deposit account agreement advising our customer of the sub-account and that it would have no effect on their account and is for internal reporting purposes only. We are looking at a new vendor for our deposit agreements and this language is not in the proposed deposit agreement that would be used. I've looked at the Federal Reserve website for assistance but I have not found anything that covers the establishment of sub-accounts and disclosing to the customer. Can anyone provide some guidance if the account agreement must disclose the sub-account usage.

Found my answer in a Federal Reserve Board of Governors letter dated May 2007. The language must be in the depositors agreement.