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#1900497 - 02/27/14 01:31 PM Customer Change Trigger New Disclosures?
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 500
If a consumer changes the way they receive their statements, for example, Joe currently receives e-statements but decides he would rather have paper statements. He requests the change however this will trigger a $3 service fee on his account. Do new disclosures need to be provided to Joe?
Thank you!!

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#1900506 - 02/27/14 01:42 PM Re: Customer Change Trigger New Disclosures? ComplianceGurl, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Either this fee was already disclosed to Joe, or you would have to provide disclosure of the possible fee 30 days in advance prior to assessing the fee.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1900512 - 02/27/14 01:54 PM Re: Customer Change Trigger New Disclosures? ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 500
We have two consumer checking accounts. One, Basic Checking, with a $3 monthly service fee that receives a paper statement. The other e-checking has no monthly maintenance fee and receives an e-statement. So if Joe opens the e-checking and decides he wants to change to paper statements, would a change form with his signature agreeing to the $3 monthly service fee suffice instead of new disclosures? Also, vice versa, customer wants to change from Basic checking to echecking, this would eliminate the $3 fee. No new disclosures correct since no fees apply? We would simply have them sign a change form going from paper statements to estatements. Something so simple seems so complicated. :-) Thanks Randy!!!

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#1900514 - 02/27/14 01:59 PM Re: Customer Change Trigger New Disclosures? ComplianceGurl, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
So you have two totally separate products. Any change between the two IMHO would trigger the delivery of new disclosures.

There is more reasons for this than just the current event. You want the initial disclosure that you deliver to refer specifically to the product you are offering. Then, in the future, if you are going to change a fee only associated with the "Basic Checking" product, your change of terms notice would refer to that specific product by name and they could match it to their own account and previous disclosures to know that the fee change is going to impact them.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1900519 - 02/27/14 02:04 PM Re: Customer Change Trigger New Disclosures? ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 500
Thanks Randy! I guess my effort in trying to save trees has failed. :-)

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