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#1750445 - 10/18/12 07:03 PM Required Disclosures for new DDA & SAV Accts
rachelchri Offline
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Joined: Aug 2010
Posts: 165
I am trying to make up a cheatsheet for our frontline employees in regards to required disclosures for our new account packets. What would the required disclosure be for a new Checking Account? and also a new Savings Account?

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Operations Compliance
#1750451 - 10/18/12 07:12 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
It might be of more value to you if you posted your first draft and asked if others could see anything you left out.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1750452 - 10/18/12 07:15 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
Compliance504 Offline
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Joined: Dec 2008
Posts: 729
Tennessee
You may want to check out the New Account Checklist in the Compliance Tools section of BOL

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#1750463 - 10/18/12 07:46 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
rachelchri Offline
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Joined: Aug 2010
Posts: 165
Thank you. I've found the checklist in BOL and it is VERY helpful!! Althought I do have a question. On the checklist it seems that the section for Reg E doesn't pertain to Savings accounts. I thought it did.

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#1750466 - 10/18/12 07:50 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
rachelchri Offline
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Joined: Aug 2010
Posts: 165
Also, the substitute check 21 disclosure: do you give that to all savings accounts or just MMDA?

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#1750490 - 10/18/12 08:06 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
1. Depends if you allow Reg E transactions on savings accounts or not.

2. Unless you are returning actual items to the customer with their statements, you don't have to give a Check 21 disclosure on any type of account.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1750504 - 10/18/12 08:20 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
rachelchri Offline
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Joined: Aug 2010
Posts: 165
rlcarey

1. We do allow customers to attach a Debit Card to their savings account.

2. This is where I get sort of confused. We give customers images of their checks with their statements (if they request) otherwise all of our checks are scanned and stored. Would Check 21 apply?

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#1750556 - 10/18/12 09:46 PM Re: Required Disclosures for new DDA & SAV Accts rachelchri
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
1. Then an EFT disclosure is required.

2. Images don't count.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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