Curious...how does everyone plan on making the disclosure FIL-38-2011 as far as wording is concerned? Does anyone have any examples? I am working on ours and while it seems simple-stupid to me, I feel as though I am complicating things and saying too much. If anyone cares to share what they have thus far, I would greatly appreciate it. You can PM me as well if you'd like.

Thanks!

Jenny

What I'm proposing is adding the same language we've used for TAGP on an account disclosure for business interest accounts. We will not automatically change accounts, however..it will be at the customer's request. One exception to that may be an account that is currently interest bearing, such as a MMDA with excessive transactions or an unqualified NOW account situation.

They would still get the disclosure sent with the notice of account change, however.

So, are you sending more of an advisory notice? If you are not going to 'automatically' change a current non-interest bearing account to an interest bearing account, then a notice would not appear to be required. If you are creating a brand new product, then shouldn't your communication be more of a marketing/announcement?