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#2238972 - 07/02/20 04:20 PM 30 Day Advance Notice to Customers Needed?
Community Banker Offline
100 Club
Joined: Nov 2008
Posts: 131
We are adding a new avenue for customers to make transactions. A shared-banking relationship. There is a minimal fee charged to the customer IF they use the service. I don't believe that this requires a 30 day advance notification, but wanted to see what others thought since this is new territory.

Thank you!

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General Discussion
#2238977 - 07/02/20 04:55 PM Re: 30 Day Advance Notice to Customers Needed? Community Banker
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,724
Illinois
Since usage of this service is not a requirement to have the account, but rather an ancillary service it does not require a change in terms notice under Reg DD. However, the fee must be prominently disclosed in whatever agreement you provide to the customer when they enroll in the service prior to their use of the service or a fee being charged.
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#2238986 - 07/02/20 05:41 PM Re: 30 Day Advance Notice to Customers Needed? Community Banker
Community Banker Offline
100 Club
Joined: Nov 2008
Posts: 131
Yes, I had thought of the fee disclosure. But I always appreciate confirmation. Thank you so much for the quick response. Your help has been tremendous!

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