We are in the process of changing the name of our FI. Obviously all of our account disclosures and terms & conditions for all of our products & services will be updated with our new logo and our new name. This will include changing our name throughout all T&C's. Will we need to provide new copies of all of our disclosures to our customers due to this change? Nothing else within the disclosures will change, just our name.

Thanks!

If nothing else is changing, then new disclosures would not be required. I am sure through your total customer communication plan the name change is being communicated through other means.

You are correct Randy. We have already released an announcement through the press. The name change doesn't take affect until early next year and I'm sure there will be more communication when it becomes closer to the actual change date.

I didn't think we would need to redisclose but wanted to verify. I appreciate your help!

we did a name change a few years back, we updated our disclosure that reflected that, but did not send new disclosures. we also did a number of customer mailings about the bank name change, targeted by what products and services they had. for example, that existing checks would continue to work but new checks would reflect new name. same for debit and credit cards. and so on through our products.

Happy, out of curiosity, did you encourage the customers to trade in their old ATM cards and checks for the ones with the new name

no, because of the involved to do at one time.

So, one more question regarding disclosures. We will obviously be re-issuing ATM/debit/business debit cards to all of our customers. Do we need to include our EFT disclosure in these mailings? All of these customers would have received this disclosure when they initially received their card, so I'm thinking no. Again - nothing has changed but our name.

However, anytime we re-issue a card now, for example to replace an expiring card, we include this disclosure.

Thanks!

To add more information to the above question:

I was just informed that we will be mailing our customers cards with new account numbers. Their old cards will only work for a period of time and then they will need to begin using their new cards. So, since these are technically brand new cards, do we need to redisclose the EFT disclosure along with the mailing? And how do we technically disclose limits to a customer who we have given different limits to aside from our default limits? Normally, the account reps provide the correct limits at account opening or card issuance, but how do we do this in a mass mailing?

I appreciate any help that can be provided! Thanks!

As long as terms aren't changing, no subsequent disclosure is needed. See the commentary to 1005.5(a)(2)

1. One-for-one rule. In issuing a renewal or substitute access device, only one renewal or substitute device may replace a previously issued device. For example, only one new card and PIN may replace a card and PIN previously issued. A financial institution may provide additional devices at the time it issues the renewal or substitute access device, however, provided the institution complies with Sec. 1005.5(b). See comment 5(b)-5. If the replacement device or the additional device permits either fewer or additional types of electronic fund transfer services, a change-in-terms notice or new disclosures are required.

Thank you Brian! I really have been reading through Reg E this morning and had not found the above commentary yet! I always seem to look in the wrong sections.....

I appreciate the info!