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#1910869 - 04/02/14 05:27 PM TISA disclosure for deposit products
GottaLuvIt Offline
Junior Member
Joined: May 2009
Posts: 48
Feedback Please: Does anyone's bank use a single TISA disclosure that includes ALL of the bank's deposit products?

For an example, if a customer seeks to open a checking account, does the TISA disclosure provided to this customer include ALL the deposit products the bank offers - checking,savings,certificates, etc.?

To me, from the customer's prespective, it seems confusing to do so as the TISA is not "clear and concise", but I haven't located anything that says it can't be done this way.

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#1910878 - 04/02/14 05:36 PM Re: TISA disclosure for deposit products GottaLuvIt
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,234
Galveston, TX
Sec. 1030.3 General disclosure requirements.

(a) Form. Depository institutions shall make the disclosures required by 1030.4 through 1030.6 of this part, as applicable, clearly and conspicuously, in writing, and in a form the consumer may keep. The disclosures required by this part may be provided to the consumer in electronic form, subject to compliance with the consumer consent and other applicable provisions of the Electronic Signatures in Global and National Commerce Act (E-Sign Act) (15 U.S.C. 7001 et seq.). The disclosures required by 1030.4(a)(2) and 1030.8 may be provided to the consumer in electronic form without regard to the consumer consent or other provisions of the E-Sign Act in the circumstances set forth in those sections. Disclosures for each account offered by an institution may be presented separately or combined with disclosures for the institution's other accounts, as long as it is clear which disclosures are applicable to the consumer's 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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#1910918 - 04/02/14 06:04 PM Re: TISA disclosure for deposit products rlcarey
GottaLuvIt Offline
Junior Member
Joined: May 2009
Posts: 48
Thank You!

It's the part "....as long as it is clear which disclosures are applicable to the consumer's account.." that concerns me.

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#1910939 - 04/02/14 06:26 PM Re: TISA disclosure for deposit products GottaLuvIt
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,234
Galveston, TX
Well, there has to be check boxes or something pointing them to the correct section of the overall disclosure to the terms that govern the specific type of account they are opening. I see few banks using all in one disclosures anymore with the automated account platforms that are available.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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