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#2023303 - 06/26/15 02:07 PM Consumer Account Product Changes
BowlingQueen Offline
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Joined: Mar 2007
Posts: 2,920
Wisconsin
We are in the process of launching online account opening through Account Create (Fiserv). In doing so, we are downsizing our consumer product offerings to 2 checking accounts, 1 savings and a MMIA. New and existing customers will be able to choose from these products once the program is in place. However, it was mentioned that we will be road-mapping (converting) most of our existing accounts from the old products to the new products (with the exception of one of the existing products that we will not convert). Also, the new products require eStatements. It is possible that there may be a fee to customers who insist on paper statements.

Here is my question. Have any of you gone through such a conversion at your bank? How did you handle the re-disclosure to the customers on a mass scale? Did you require the customers to sign anything (i.e. signature cards) to gain their acknowledgment of the product change? Did you allow the customers to choose which checking product they want? How well did this go over with your customers? Any other things to consider or suggestions?

Your comments are very welcome! Thank you!
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#2023307 - 06/26/15 02:12 PM Re: Consumer Account Product Changes BowlingQueen
rlcarey Offline
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Galveston, TX
Also, the new products require eStatements.

You cannot force e-statements on anyone - period.
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#2023315 - 06/26/15 02:23 PM Re: Consumer Account Product Changes BowlingQueen
BowlingQueen Offline
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Wisconsin
There must be a way to do this, as many other banks manage to do so, no?
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#2023324 - 06/26/15 02:50 PM Re: Consumer Account Product Changes BowlingQueen
rlcarey Offline
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rlcarey
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Galveston, TX
No. You can offer e-statements, you can offer a discount on monthly maintenance fees if they sign up for e-statements (I prefer offering a discount rather than charging them a direct fee for the delivery of paper statements, as you are required by law to provide them), but the fact of the matter remains, unless the consumer agrees to e-statements and you go through the demonstrable consent procedures required by the E-Sign Act, you cannot force anyone into accepting e-statements.

As far as converting accounts - it happens all the time. Send them their new depositor's agreement that governs their new account type and their new TISA disclosure at least 30 days in advance of the change. In the cover letter, you can tell them if they would prefer a different account type, they are free to come into the branch and discuss additional account options. Otherwise, use the account after XX/XX/XX date will constitute their agreement to the new terms.

Get your legal counsel to assist you in drafting the appropriate language.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2023343 - 06/26/15 03:07 PM Re: Consumer Account Product Changes BowlingQueen
BowlingQueen Offline
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Wisconsin
Thanks Randy!
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#2023779 - 06/29/15 05:41 PM Re: Consumer Account Product Changes BowlingQueen
RR Jen Offline
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We just went thought a big conversion of accounts. All of ours now come with free e-statements, you pay should you choose paper. (personally, I voted for Randy's option of a reduction of fee versus hard charge but lost)

We sent a letter very similar to what he mentioned and had branch mangers contact larger commercial customers in advance and walk them through the process.
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#2025438 - 07/06/15 08:14 PM Re: Consumer Account Product Changes BowlingQueen
DTR-ISB Offline
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Joined: Jul 2013
Posts: 3
Iowa
We are looking into offering an e-statement only account and giving the customer 60 days to enroll in e-statements. If they do not enroll after 60 days, we will automatically convert the account to a "regular" checking which may be subject to fees based on average balances, etc. This potential change would be spelled out in the e-statement account TIS. We will call the customer at 30 days to remind them to enroll, then at 60 days we will to send a letter along with the new TIS for the "regular" checking account. Has anyone done anything similar to this? We are struggling on how our 60 day letter should read. Anyone have a template they could share? Thanks!

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#2025445 - 07/06/15 08:27 PM Re: Consumer Account Product Changes BowlingQueen
rlcarey Offline
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Galveston, TX
then at 60 days we will to send a letter along with the new TIS for the "regular" checking account.

And then convert the account 30 days after that???? You have to give them 30 days advance notice of the changes.

Why in the world would you put your customer base through such a hassle.

Covert them all and offer them e-statements if they want to avoid the new fees. If you structure it in this manner that makes the people that do not want e-statements feel pressured and alienated by the bank, they are going to leave in droves.

Someone at your institution needs to go bank to marketing school.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2025557 - 07/07/15 02:19 PM Re: Consumer Account Product Changes BowlingQueen
DTR-ISB Offline
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Joined: Jul 2013
Posts: 3
Iowa
If we have everything disclosed in the e-statement account TIS that the account requires e-statements, is the 30 day change notice required? That is part of the initial account set-up, e-statements are required for the account. The customer is aware of this PRIOR to opening up the account. This will have NOTHING to do with the current customer accounts....it is a new account product....only new accounts that are opened as the e-statement account will be affected, not current accounts.

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#2025569 - 07/07/15 02:39 PM Re: Consumer Account Product Changes BowlingQueen
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
OK - sorry, but you tacked your question onto a thread that was discussing change of terms that are required on existing accounts and not offering a new account product. That is the danger of changing horses in midstream - some people may not following exactly what you are trying to say.

I would disclose both sets of fees and charges in the initial disclosure clearly telling them what the fees and charges will be after 60 days if they do not sign up for e-statements.

As far as the 60 day letter, since the disclosures have already been made, let your marketing folks write it.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2034617 - 08/19/15 07:02 PM Re: Consumer Account Product Changes BowlingQueen
Snowmann Offline
Member
Joined: Feb 2011
Posts: 51
Scenario: An employee is speaking to a customer over the phone about a new line of deposit products. The customer chooses to convert to one of the new deposit product (but is not forced to covert to a new one).

Is the customer's signature required at any point during this coversion to a different account type? Or would the delivery of proper TIS disclosures and deposit agreements (before switching the account type) suffice?

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#2034870 - 08/20/15 04:03 PM Re: Consumer Account Product Changes BowlingQueen
Naise Offline
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Joined: Feb 2014
Posts: 91
You actually don't need to send the TISA before the switch if you're doing it by phone:

Except as provided in paragraph (a)(1)(ii) of this section (FYI - this is referring to online account opening), if the consumer is not present at the institution when the account is opened or the service is provided and has not already received the disclosures, the institution shall mail or deliver the disclosures no later than 10 business days after the account is opened or the service is provided, whichever is earlier

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