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#1371371 - 04/08/10 05:41 PM REG E - Joint account owners
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
I understand that consent from one account owner can be considered affirmative consent.

However, do we notify all account owners of a joint account? I've not seen that. In my opinion we would. I'm being challenged that only the primary account holder be notified. Either party can revoke - so why wouldn't notification go to either party. Maybe i'm not looking in the correct place.

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#1371445 - 04/08/10 07:01 PM Re: REG E - Joint account owners Tryin-2-Comply
Georgia Plum
Unregistered

I assume you are asking about the Opt-In notification.

I would address to both account owners at the statement address. It only takes one of the owners to consent.

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#1371473 - 04/08/10 07:37 PM Re: REG E - Joint account owners
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
I agree - thank you and yes, it is the Opt-in - been a crazy week.

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#1371475 - 04/08/10 07:38 PM Re: REG E - Joint account owners Tryin-2-Comply
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
Another question - so are you saying that you would sent one notification with both owners being addressed?

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#1371522 - 04/08/10 08:20 PM Re: REG E - Joint account owners Tryin-2-Comply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
That's what I suggest. Either owner can open the bank statement; either can opt-in; either can revoke. Unless there's a requirement in the regulation to separately notify each owner (there isn't) why go to that expense and aggravation?
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#1371656 - 04/08/10 11:39 PM Re: REG E - Joint account owners John Burnett
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
Thank you - i agree.

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#1394785 - 05/21/10 06:52 PM Re: REG E - Joint account owners Tryin-2-Comply
Oviedo Boy Offline
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Joined: May 2006
Posts: 629
Tennessee
But, would it be a violation if the Notification was sent ONLY to the Primary account holder?
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#1395067 - 05/24/10 02:10 PM Re: REG E - Joint account owners Oviedo Boy
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
I don't see how it could be termed a violation because the regulation makes no mention of how to notify joint owners. As I said above, the best case would be a mailing showing all joint account owners in the address. But I hardly think it would be a violation if you only named one of them.
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BankersOnline.com
Fighting for Compliance since 1976
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