Our chief risk officer just brought this to my attention. Apparently our new account employees have been changing the name of our savings accounts from Savings to Christmas Club upon request by the customer at account opening. The terms and fees for both are the same, but the problem is we no longer offer Christmas Club accounts and so they are not listed in our TIS Brochures. Would this be a TISA violation? UDAAP? I've never come across this before so any input would be much appreciated.
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Serenity Now!!!