Hello!!

We are currently in the process of revamping our retail and commercial checking and savings accounts. We will be changing balance requirements and account related fees. We will be sending a change in terms notice to existing customers informing them of the upcoming changes, the notice will be sent at least 30 days prior to the effective date of the change. For new accounts that are opened after the change in terms notice is sent but before the effective date of the change, are we permitted to provided two sets of TISA disclosures? The fist would be the current TISA disclosure reflecting the terms under which the account is opened, the second would be a revised TISA disclosure highlighting the changes that will be made to the account on the effective date.

We decided to take this approach because consumers that open accounts after the notice mail date but before the effective date of the changes will be over the 30 day notification requirement under TISA. I am getting conflicting responses regarding this approach.

Any help would be greatly appreciated!

Yes, we went thru the same thing about two years ago and we provided the customer with the old information and the new information right up until the date of implementation at which time the system provided the new correct disclosures needed.