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#2216142 - 06/20/19 03:51 PM Back of Periodic Statement for DDA & Savings
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Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
I am reviewing the back of our periodic statement and the following disclosure is present. It has some similar elements to the Alternative Billing-Error Rights disclosure but it is not the same.

Does this look familiar? Can you point me to where I can find this disclosure or requirement?

In Case of Errors or Inquiries About Your ACCOUNT Statement
Send your inquiry in writing on a separate sheet to the bank address shown at the
top of the reverse side so that we receive it within 60 days after the statement was mailed to you.
Your Written inquiry must include:
1. Your name and account number.
2. A description of the error and why (to the extent you can explain) you believe it is an error; and
3. The dollar amount of the suspected error.
If you have authorized us to automatically charge your account, you can stop the
payment on any amount you think is wrong by mailing your notice so that we receive it within 3 business days before the scheduled payment date. You remain obligated to pay the parts of your statement not in dispute, but you do not have to pay any amount in dispute during the time we are resolving the dispute. During the same time, we may not take any action to collect disputed amounts or report disputed amounts as delinquent.
This is a summary of your rights; a full statement of your rights and our
responsibilities under the Federal Fair Credit Billing Act will be sent to you both upon request and in response to an Account Statement error notice.
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Deposits and Payments
#2216150 - 06/20/19 05:01 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
Adam Witmer Online
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Posts: 2,628
It looks similar to Model form G-3 under Reg Z, but isn't the exact model language. That would be a disclosure for open-end credit.
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#2216162 - 06/20/19 06:57 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
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Diamond Poster
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Posts: 1,060
In the mountains
Is there a requirement to have a Reg Z billing error resolution disclosure on a deposit account periodic statement?
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#2216166 - 06/20/19 07:15 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
BrianC Offline
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BrianC
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Illinois
Many statement backs have it to cover institutions that offer overdraft lines of credit that appear on the same statement as the checking account to which they are attached. If you do not have any accounts with open-end credit that are using this statement paper, then no it is not required.
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#2216173 - 06/20/19 07:47 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
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Diamond Poster
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Posts: 1,060
In the mountains
We have an overdraft program but it not a line of credit under Reg Z so I seems we are ok to omit it.

Thanks!
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#2216191 - 06/20/19 09:03 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
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Diamond Poster
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Posts: 1,060
In the mountains
Wait...is it required if we have a HELOC that is tied to a checking account? The customer accesses the HELOC via writing checks in a checking account, so the statement shows the checks written and the transfers from the HELOC to cover the amount. The HELOC gets a bill with the Billing Rights, but must the checking account periodic statement also include a Billing Rights disclosure? If so, can we use what I typed in my opening comments above even though it is more like the alternative disclosure for the credit card statement?

I ask because using the alternative disclosure for a HELOC on a periodic bank statement is not going to make much sense since the bank statement is not a bill.
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#2216196 - 06/20/19 09:16 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
If you are delivering separate statements - no. If your overdraft line periodic statement is combined with the checking account periodic statement, then you would need the billing rights statement also, unless you are delivering the annual notice separately.
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#2216222 - 06/21/19 12:37 PM Re: Back of Periodic Statement for DDA & Savings Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
Thanks!!!!
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