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#1842924 - 08/15/13 06:42 PM Closing account type

If we are discontinuing an account type and will no longer offer it to new and existing customers and are trying to phase account the existing accounts that are still open- how do we do this? Is a change in terms required or just a best practice? I didn't see anything in Reg DD that requires a 30 day notice, but I don't see why we wouldn't want to provide one. But would we need to provide only to those with this type of account, or all existing customers?

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#1844168 - 08/20/13 05:54 PM Re: Closing account type Anonymous
James M. Moore Offline
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James M. Moore
Joined: Jul 2013
Posts: 110
The simple answer is to send a full truth in savings disclosure to all customers 30 days in advance and then convert the accounts to the new account type.

You are only technically required to provide a change in terms notice if:

Change in terms. (1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under Sec. 1030.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer. The notice shall include the effective date of the change. The notice shall be mailed or delivered at least 30 calendar days before the effective date of the change.
James M. Moore, CRCM
My postings are not legal advice and may not be endorsed by my employer.

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