I understand why there is debate because the regulation uses the term "established."
229.13(a)(2) An account is considered a new account during the first 30 calendar days after the account is established
That being said, I agree with John and Randy that what drives the new account definition is what is said next places the focus on the length of the customer relationship.
An account is not considered a new account if each customer on the account has had, within 30 calendar days before the account is established, another account at the depositary bank for at least 30 calendar days.
So let's consider the operational discussion.
Employee A: "Oh, it's not a new account because the account was established more than 30 days ago even though we just added the brand new joint owner.
Employee B: Great, since I want to protect the bank, make the individual owner close the account and 'establish' a new account with a new number so that we can call it a new account."
Employee A: "But that will really inconvenience the original customer because they have all their automatic payments that they'd need to transfer to the new account just so we can have Reg CC protections."
Employee B: "So since regardless of what we do operationally we end up with a joint account involving one existing customer and one new customer, and the only difference is the 'account open date' maybe we can just treat the account as new when the new person is added and leave the account number the same."
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