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#2247917 - 01/21/21 02:39 PM TISA Disclosures & Online Account Opening
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 1,046
Midwest
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!

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#2247918 - 01/21/21 02:46 PM Re: TISA Disclosures & Online Account Opening Bankwoman1
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
The 10 business day rule is limited to request for information and not account opening.

Except as provided in paragraph (a)(1)(ii) of this section, if the consumer is not present at the institution when the account is opened or the service is provided and has not already received the disclosures, the institution shall mail or deliver the disclosures no later than 10 business days after the account is opened or the service is provided, whichever is earlier.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2247922 - 01/21/21 03:00 PM Re: TISA Disclosures & Online Account Opening rlcarey
Bankwoman1 Offline
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Midwest
But am I understanding this section correctly to NOT include accounts opened online?

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#2247924 - 01/21/21 03:15 PM Re: TISA Disclosures & Online Account Opening Bankwoman1
rlcarey Online
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rlcarey
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Posts: 83,219
Galveston, TX
(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.

So, when do you you consider the account opened? When do you allow them to fund the account?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2247926 - 01/21/21 03:31 PM Re: TISA Disclosures & Online Account Opening Bankwoman1
Bankwoman1 Offline
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Midwest
The account would be opened after it is approved by a bank employee, so not immediately, but more like next day. We will be allowing the customer to fund the account by ACH, mail-in check/cash or internal transfer.

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#2247927 - 01/21/21 03:36 PM Re: TISA Disclosures & Online Account Opening Bankwoman1
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Then at that point it is opened and disclosures must be provided before that time.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2247933 - 01/21/21 04:28 PM Re: TISA Disclosures & Online Account Opening Bankwoman1
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 1,046
Midwest
Ok...thanks for your help Randy. I appreciate it.

We will figure it out!

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#2247978 - 01/21/21 10:52 PM Re: TISA Disclosures & Online Account Opening Bankwoman1
TryingtoComply Offline
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Joined: Apr 2013
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The West
We have a similar situation. The customer submits their "application" to open an account online, we review/approve it and then send the TISA disclosures along with other information and instructions for funding.
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