We are in the process of setting up our new online account opening site. I am working on getting all disclosures that need provided at account opening set up so that they can be accessed from the new platform. My question is, when providing the Truth-in-Savings disclosures, the rate information and date the rate is accurate will not be on the disclosures because they will possibly change. We are having a tough time figuring out how to get this information onto the disclosure. Reg DD states:
(ii) Timing of electronic disclosures. If a consumer who is not present at the institution uses electronic means (for example, an Internet Web site) to open an account or request a service, the disclosures required under paragraph (a)(1) of this section must be provided before the account is opened or the service is provided.
Can these disclosures be mailed after the account is opened and approved but no later than 10 business days after? I know "service" is deemed to have been provided when a fee has been assessed. However, not all of our accounts have "fees".
Trying to figure out the best way to provide the disclosures in the proper timeframes.
Thanks!