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#1911524 - 04/03/14 11:24 PM Combined Account Opening Disclosures
Multiple Hats Offline
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Joined: Jul 2008
Posts: 204
We are looking into combining a lot of our deposit account opening disclosures into a single booklet. All the deposit account (checking, savings, money market)disclosures will be combined together in one section. The combined disclosures won't list a rate or effective date to keep us from having to make a new book each time rates change. A seperate interest rate sheet will be put in the book and changed when rates move. The booklet disclosure will instruct the consumer to "see attached rate sheet". I'm worried doing like this might not be clear and conspicuous. Does anyone else have a system like this?

Reg DD requirements are below: General Requirements (230.3(a) and (b)) Section 230.3 outlines the general requirements for account disclosures and periodic statement disclosures.
Such disclosures are required to be
Clear and conspicuous;
In writing;
In a form the consumer may keep;
Clearly identifiable for different accounts, if
disclosures for different accounts are combined;
Reflective of the terms of the legal obligation of
the account agreement between the consumer
and the depository institution;
Available in English upon request if the disclosures
are made in languages other than English;
and
Consistent in terminology when describing terms
or features that are required to be disclosed.

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#1911531 - 04/04/14 12:14 PM Re: Combined Account Opening Disclosures Multiple Hats
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,893
Galveston, TX
Banks use a separate rate sheet all the time.


I would be much more concerned about this. Are there going to be check boxes or something that indicates which distinct disclosures apply for the specific account or accounts the consumer sitting in front of you is opening??

Clearly identifiable for different accounts, if disclosures for different accounts are combined
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#1911559 - 04/04/14 01:05 PM Re: Combined Account Opening Disclosures Multiple Hats
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
Will the "booklet" be manually marked for the applicable disclosures? Disclosures coming off a system have boxes checked or, alternatively, just provide the applicable disclosures. That will be more difficult in a hard copy booklet, unless this "booklet" will be printed with each account.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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