We are looking into allowing customers when they use their debit card to round up to the next dollar and either donate the difference to Hurricane Michael Relief or have it go into their savings account. Does any one have this program and what kind of disclosure did you provide? There was a forum that mentioned this from 2008 and they said this was a contract not governed under the common compliance.
Thank you.

Ahhh, memories of being a lobby banker, circa 2005/2006. We called it "Change is Good" and for each Db card transaction on a regular checking account, we rounded up to the nearest dollar and put the pennies in the customer's Savings account. As I remember, there was no extra or special forms for the customer, they just gave their consent (maybe on a form), and it was set up in the back office to count & move the pennies. Each day's pennies were accumulated to make just one daily deposit.

The biggest challenge was defining the end points: which checking products do you want to transfer from, and which savings products catch the 'Change.' Be ready to explain why someone can't catch those pennies in a Money Market a/c. And think about how you'll treat the situation where a fraudulent Db card transaction gets backed out after its pennies post to Savings.

Marketing thought it was a great idea, but it lasted about 16 to 24 months before it burned out and had to be cleaned up: all those connections had to be undone, and I can't remember exactly how we notified customers that the program/product was ending.

So this subject has just come up in my bank as well. I can't figure out any specific disclosures that have to be provided. Is that your conclusion also? I'm feeling a little nervous about my opinion.

Just look up the BOA "keep the change" program, they have useful information about disclosures.