I am new to deposit compliance and need help.
We currently offer an HSA checking account (#1) that we market to employees of business customers. We also offer an HSA checking account (#2) to anyone else who wants it. The two products have different features: #1 is an interest bearing account, has no minimum amount to open or minimum balance requirements; #2 is a non-interest bearing account, has a minimum balance requirement. Account #1 holder receives notification in the account opening disclosures stating that if they seize the employment with the Bank’s business customer, their account type will be converted to #2 and will have fees and features of the account #2.

The area who processes product changes from #1 type to #2 upon the receipt of employment termination from the businesses customers make the changes when the employment is terminated. They do not send change-in-terms notices as they rely on the fact that the customer was notified of their eleigibility for the product at the time of the account opening. I think that we still need to send a notice at least 30 calendar days before the effective date of the change. Please let me know if I am on the correct path. Thanks