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#2227229 - 12/11/19 09:22 PM Reg DD - Dormant Timeframes
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,120
Are we required to disclose dormant timeframes in our TIS disclosures? It's not required under 1030.4(b), unless I missed it. We have a standard dormant account paragraph in our Deposit Account Agreement, but it doesn't get into specific timeframes (i.e. 24 months). Is that good enough? I have a feeling someone before my time just added it in the TIS as 'extra' information.

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#2227230 - 12/11/19 09:25 PM Re: Reg DD - Dormant Timeframes Mel in WA
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,011
Illinois
If you charge a dormancy fee, you are required to disclose the circumstances under which a fee is charged which would include the length of inactivity before a fee is charged.
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#2227232 - 12/11/19 09:40 PM Re: Reg DD - Dormant Timeframes Mel in WA
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,120
We refer to our Miscellaneous Fee Schedule for all fees, including dormant. If the timeframe and fee amount are clearly outlined there, we don't need it in the TIS, correct? I'm not a fan of repeating information in two places.

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#2227234 - 12/11/19 09:44 PM Re: Reg DD - Dormant Timeframes Mel in WA
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,011
Illinois
Correct. You don't have to redundantly say things more than once. wink
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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