We currently have all TISA required fees disclosed on the TISA disclosure. With a recent update to our platform software the margins of the disclosure reduced significantly and there is not enough room to include all of the required fees. Someone suggested not having the specific fees on the disclosure but only a statement referring the customer to the fee brochure which includes all bank fees including the ones required by TISA. The new accounts employee would in turn attach a copy of the fee brochure to the disclosure with each new account opened. Is this acceptable? Maybe I have taken the reg too "literal" and have always believed if it is required to be disclosed then it should be on the disclosure. Any thoughts?

We make a good faith effort to get the main fees associated with an account on the TISA disclosure. Generally these are the fees for a spcific account (monthly maintenance, etc).

However we have some ancillary fees and additional service fees which we say please refer to the attached schedule of charges... which repeats the fees of the specific account and all the additional fees that might possibly be charged by the bank.

Hope that helps.

Cheers!

Yes, that is fine; we did it for years. We included a reference incorporating the Fee Schedule in each TISA disclosure. The system automatically generated the Fee Schedule along with each TISA.