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#1552938 - 05/18/11 02:37 PM Reg CC Changes
Auditgirl50 Offline
Member
Joined: Feb 2009
Posts: 62
Texas
Our IT department did an update last night. Our new account disclosures are now showing the first $200.00 as available and funds may be available on the ninth business day instead of the eleventh.

My question is: Will this be a problem with the regulators? Since it is to the customer's favor, I think that will be fine. What do you all think?

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Audit
#1553404 - 05/18/11 07:31 PM Re: Reg CC Changes Auditgirl50
Goal Keeper Offline
Member
Joined: Jun 2006
Posts: 71
We have done this in the past with no problem from the regulators. And the customer gets the benefit.

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#1553565 - 05/19/11 01:18 AM Re: Reg CC Changes Goal Keeper
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
You will have to notify your existing customers within 30 days of making the change - even if it is in their favor.

229.18(e) Changes in policy. A bank shall send a notice to holders of consumer accounts at least 30 days before implementing a change to the bank's availability policy regarding such accounts, except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1554767 - 05/20/11 06:21 PM Re: Reg CC Changes rlcarey
Auditgirl50 Offline
Member
Joined: Feb 2009
Posts: 62
Texas
Thank you very much...we are getting notices ready now. I appreciate all the help from BOL and its members. Such a great resource!

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#1557509 - 05/26/11 08:31 PM Re: Reg CC Changes Auditgirl50
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Regulators wouldn't care that you jumped into this early. You are proactive to providing consumers with this "advantage."
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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