If the customer is a consumer, you will need to ensure that the TISA disclosures provided reflect the rate, terms and conditions that apply to the account, rather than those that might be generated for the "vanilla" version of the account. If there will be any balance requirements for other accounts, you'll need to ensure you have a good monitoring system for those balances.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8