If we have new account types and plan on changing migrating existing customers to those new account types would this be a change in terms requiring 30 day notice or a new account as describe below in the commentary? My initial thoughts were a change in terms but we rely on the following when switching customers from an a savings account to a demand deposit when they have excessive transactions.

iii. An institution transfers funds from an account to open a new account not at the consumer's request, unless the institution previously gave account disclosures and any change-in-term notices for the new account.

As far as I know, it's a change requiring 30 days notice. That's how we did it anyway when we recently switched our customers over to a different account type (as we were ceasing to offer the previous one). If I'm wrong, someone please enlighten me.

I agree. That's how we did it in a previous life. And don't forget to send the new account disclosure with the notification.

Yes, a 30 day notice must be given

What about transferring accounts do to excessive transactions under reg d? What situations would the reference from the original post be talking about?

There is no way to answer these questions without doing a side by side comparison of the two disclosures.

Advance notice is only required when you are changing a term that TISA requires you to disclose. Assume TISA requires 11 disclosures for Account A. If Account B has the same 11 features, you can make your change without advance notice.

If I'm changing account types in order to comply with Regulation D there isn't going to be any foreplay; I'll tell them what has been done as a result of their failure to adhere to transaction limitations that were disclosed to them, not what I'm a fixin' to do.

Besides the change in disclosure and terms if your customer has direct deposit into the previous account they need to inform their employer of the account type change. Some companies take two or three weeks for the change to take affect.

If the account number and routing number remains the same I don't believe it will have an effect on direct deposit.

It might. NACHA has separate transaction codes for savings accounts and checking accounts. Many systems will reject the ACH if the wrong transaction code is used.