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#2016642 - 05/28/15 04:37 PM Reg DD Question

My shop currently uses the WKFS TIS Disclosure. Due to system issues, we would prefer to disclose the minimum balance to open the account on our rate sheet, as opposed to the WKFS TIS Disclosure. Is it permissible to use a combination of the WKFS TIS Disclosure and rate sheet to comply with the TISA?

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#2016699 - 05/28/15 06:21 PM Re: Reg DD Question Anonymous
NSF, CRCM Offline
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Joined: Apr 2013
Posts: 410
I don't believe this will work. REG DD states that the minimum balance information, if applicable, has to be part of the TIS disclosure. See 1030.4(b)(3)

What system issues are you guys having with WKFS? Currently they are our forms provider as well and I haven't noticed any problems.
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2016705 - 05/28/15 06:39 PM Re: Reg DD Question Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The regulation, via the commentary, does not require that all disclosures be on the same piece of paper. See subparagraph vi:

(a) Form.

1. Design requirements. Disclosures must be presented in a format that allows consumers to readily understand the terms of their account. Institutions are not required to use a particular type size or typeface, nor are institutions required to state any term more conspicuously than any other term. Disclosures may be made:

i. In any order.

ii. In combination with other disclosures or account terms.

iii. In combination with disclosures for other types of accounts, as long as it is clear to consumers which disclosures apply to their account.

iv. On more than one page and on the front and reverse sides.

v. By using inserts to a document or filling in blanks.

vi. On more than one document, as long as the documents are provided at the same time.

Nevertheless, without more information, this does not seem like a good idea. At a minimum, make certain the vendor disclosure and the one you are supplying are not in conflict with one another.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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