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#2216661 - 06/27/19 07:21 PM TISA & Periodic Statement
Anonymous
Unregistered

Curious if anyone has been cited by a Regulator for the fees disclosed on the TISA (ex: maintenance fee) versus the fee disclosed on the periodic statement? Our statements refer to a maintenance fee in the body (history) of the statement but at the top of the statement (discloses beginning balance+credits-debits-fees=ending balance) and the fee is referred to as a service fee.

We are being told we have a TISA violation.

Thanks in advance!

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#2216664 - 06/27/19 07:29 PM Re: TISA & Periodic Statement Anonymous
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
Unfortunately, yes. Many years ago - and if I remember correctly we also got dinged because it didn't match on the service charge brochure we were providing to customers, so you may want to check that as well. The Examiners really want to see consistency so the customer does not get confused.
_________________________
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#2216683 - 06/27/19 09:57 PM Re: TISA & Periodic Statement Anonymous
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I see this at nearly every new client we pick up. Reg DD is very clear that the wording must be consistent in all places. It's not a "big" violation, but it's a violation. As 80's Lady said, check everywhere you mention fees: website, brochures, TISA disclosures, periodic statements, etc.
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David Dickinson
http://www.bankerscompliance.com

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