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#2099619 - 09/21/16 01:36 PM Reg CC disclosure and online account opening
1 Peter 5:7 Offline
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1 Peter 5:7
Joined: Jun 2001
Posts: 1,339
So if an existing customer may open an additional deposit account online through online banking, would it be acceptable for the 229.16 Specific Availability disclosure to be mailed to the customer? Or does the disclosure have to be provided AT account opening? If the latter, is an electronic provision of it OK through a click and download? Or is an additional disclosure even necessary (not a potential customer)? Thanks for your help.

"Sec. 229.17 - Initial disclosures.
Before opening a new account, a bank shall provide a potential customer with the applicable specific availability policy disclosure described in Sec. 229.16."
Opinions are mine not my employer's, and should not be taken as legal advice.

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#2099647 - 09/21/16 03:46 PM Re: Reg CC disclosure and online account opening 1 Peter 5:7
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,785
Cape Cod
See 229.15(c). If the customer is opening a new account to which the same availability policies apply as those applicable to another account the customer already has with you, you don't need to provide another disclosure for the new account.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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