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#2235865 - 04/28/20 09:31 PM Reg CC 7/1/20 statement wording
Red Raiders Offline
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Red Raiders
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Compliance Land
We are a CSI bank and i really would like to use a statement message to notify our customers of the upcoming Regulation CC change. We are limited to 4 lines and 60 characters per line. Think this is clear enough for our customer notice:

On 7/1/20, the amount available for withdrawal by checks
not subject to next day availability is increasing to $225.
The amount available for withdrawal on exception holds for
large deposits and new accounts is increasing to $5,525.
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#2235882 - 04/29/20 01:38 PM Re: Reg CC 7/1/20 statement wording Red Raiders
John Burnett Offline
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I think it's clear enough if it covers all the amounts affected by the change in your new account funds availability disclosure. Don't forget that you can send this anytime up to 30 days following your implementation of the new amounts. And, subject to third-party capabilities, you can make the change anytime from now until July 1.
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#2235907 - 04/29/20 03:09 PM Re: Reg CC 7/1/20 statement wording Red Raiders
Susielou Offline
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Joined: Aug 2005
Posts: 323
Midwest
Should we be telling from what amount is changing? The amount will change from $200 to $225?

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#2235957 - 04/29/20 08:55 PM Re: Reg CC 7/1/20 statement wording Red Raiders
John Burnett Offline
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Not necessarily, but I agree it would make it clearer to the customer what you are referring to. It also shows how much (or how little) the increase is.
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#2236053 - 05/01/20 04:42 PM Re: Reg CC 7/1/20 statement wording Red Raiders
Red Raiders Offline
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The only options we have are:

1. That statement message from my original post
2. A direct mail to all affected accountholders (separate from a statement)
3. A statement insert to all DDA and savings customers that would include a statement that it only applies to xxxx, xxxx and xxxx accounts or maybe that it applies to all accounts but xxxx, xxxx, and xxxx.

#1 is my favorite and is the easiest and cheapest. #2 is my least favorite because it is way more costly than #1 or #3. #3 is eh ok. Our system isn't capable of only sending a statement insert with certain account types, unfortunately. That is why for #3 it would have to be sent to all with the disclaimer if we chose this route.
Last edited by Red Raiders; 05/01/20 04:43 PM.
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#2236075 - 05/01/20 08:39 PM Re: Reg CC 7/1/20 statement wording Red Raiders
Helpcompliance Offline
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Joined: Mar 2015
Posts: 27
Kentucky
We are also a CSI bank and we used option #3. We contemplated using the statement message, but we felt more comfortable using the statement insert. This process was a little more work, but we felt the customer notice the insert and understand the changes better by using an insert. CSI needs to offer additional space for statement messages!

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#2236077 - 05/01/20 08:46 PM Re: Reg CC 7/1/20 statement wording Helpcompliance
Red Raiders Offline
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Did you say somewhere on the disclosure that it doesn't apply to Savings and Money Market accounts (for example) or how did you word it? We haven't decided exactly how we are going to word it.
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#2236078 - 05/01/20 08:59 PM Re: Reg CC 7/1/20 statement wording Red Raiders
Helpcompliance Offline
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Joined: Mar 2015
Posts: 27
Kentucky
We updated our current Reg CC notice (one page); we bolded the changes in the notice, and we added a paragraph at the top explaining the changes, then we put * by the changes in the explanation paragraph at the top and in the Reg CC notice details.

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