I have seen this question raised in other threads but always mentioning that the disclosure would be very short but I am curious if a TISA "disclosure" would need to be provided at all if an account did not bear interest, had no minimum balance requirements, and had no transaction limitations? A fee schedule is provided to cover the fees requirement but would something else be necessary?

Please describe the account further, such as - open-end, closed-end, duration, dollar amounts, etc.

Sorry, just a standard checking account. Non-interest bearing, no minimum balances, and no transaction limitations.

Well dang - you said TISA and I was thinking TILA

Well the disclosures required under 1030.4 only have to be made as applicable and if none of them are applicable, then what are you going to disclose? There is no requirement to disclose in the negative.

Ok perfect. It seemed silly to send a document out that didn't say anything but I was having trouble squaring the requirement to provide a disclosure.

Thank you.

Always look for the words "as applicable!"