Okay, I really haven't been paying attention if any new regs have come out concerning HSAs because we don't offer them. However, I've been invited to a meeting to discuss offering HSAs. Anyone have a checklist of things to consider or have any links to regulations governing said creatures? Thanks in advance.

"Anyone have a checklist of things to consider"

First thing on the list is a profit and loss analysis - everything comes next.

They are losers unless you have a plan to gather a lot of them and charge appropriately- the adminstration costs alone far outstrip any other type of deposit product.

To consider:

Contract management
IRS reporting
Customer service issues
split year deposits
training, training, and more training
to name a few

I agree with Randy. And also, be prepared with how you will deal with overdrafts - because even though they are not suppose to be able to overdraw, because most HSA's come with a Debit Card, it will happen. It is my understanding that the account can no longer be considered an HSA and IRS Reporting Rules will have to be followed.

If you are located in California you may want to check if the state has conformed with the federal regulations that allow for HSA contribution tax benefits. Since we don't offer HSAs I'm curious to know if other FIs that do offer them in California issue both a 5498 for federal reporting and a 1099-INT for state reporting.

The OCC has some guidance in any new adventure - http://www.occ.treas.gov/ftp/bulletin/2004-20.doc

Risk Management of New, Expanded, or Modified Bank Products and Services

It actually makes sense.