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#2248160 - 01/26/21 03:47 PM Providing Account Disclosures
corporate audit Offline
Junior Member
Joined: May 2008
Posts: 31
Are initial disclosures required to be provided when a new account is opened for a customer due to an account takeover due to fraud?

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Operations Compliance
#2248162 - 01/26/21 03:58 PM Re: Providing Account Disclosures corporate audit
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,240
Illinois
It's a new account. Yes.

1030.4(a) Delivery of account disclosures. (1) Account opening. (i) General. A depository institution shall provide account disclosures to a consumer before an account is opened or a service is provided, whichever is earlier.
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#2248453 - 02/01/21 02:12 PM Re: Providing Account Disclosures corporate audit
corporate audit Offline
Junior Member
Joined: May 2008
Posts: 31
So even if it is the same type of account the initial disclosures are required?

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#2248454 - 02/01/21 02:19 PM Re: Providing Account Disclosures corporate audit
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
Define opening an account. You mean you are just assigning them a new account number? If that is the case, then I would not get too concerned over it as long as you are sure that they have received proper disclosures previously.
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