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.