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#2237187 - 05/22/20 10:31 PM Change from Interest to Non-Interest Bearing Acct
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
We recently had a request from a customer to convert their account from an interest bearing account to a non-interest bearing account. They happened to make this request on the day before their statement cut off, so they did not receive the interest that had accrued. They asked for it, and we calculated in manually and gave to them.

Our disclosures do not address this type of situation (converting and account) - only that an "account closure" results in the forfeiture of interest accrued.

Has anyone provided for this in their general account disclosure? It's not a common request, but I'm just wondering if we should consider adding something at the next update to our disclosures.
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General Discussion
#2237188 - 05/22/20 10:40 PM Re: Change from Interest to Non-Interest Bearing Acct TryingtoComply
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
Reg DD only requires a disclosure for what happens to accrued interest if an account is closed prior to interest being credited. Adding a disclosure that is not required (and for which there is no model language) to address a rare request is not something I'd recommend. If you want to have something in your procedures that directs staff how to handle these requests consistently, that's fine.
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#2237189 - 05/22/20 11:29 PM Re: Change from Interest to Non-Interest Bearing Acct TryingtoComply
TryingtoComply Offline
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Joined: Apr 2013
Posts: 2,199
The West
Thanks Brian. Good point. And I like your recommendation!
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#2237434 - 06/01/20 06:56 PM Re: Change from Interest to Non-Interest Bearing Acct TryingtoComply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You did provide disclosures for the new account, right?
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#2237457 - 06/02/20 01:02 PM Re: Change from Interest to Non-Interest Bearing Acct TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Yes, our employees know to deliver disclosures when converting accounts to another type.
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