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#2265906 - 02/07/22 03:22 PM CRA BOOK
Amy S Offline
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Joined: Sep 2020
Posts: 139
In our binder we have available to the public, is it necessary to have all account terms & conditions in the binder or can we just provide them if requested?

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#2265909 - 02/07/22 03:35 PM Re: CRA BOOK Amy S
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,651
Galveston, TX
If they ask to review your CRA Public File, a list of services has to be included, so I guess I do not understand your questions (12 CFR 228.43(a)(5))

What do you mean account terms and conditions? You mean in addition to the list of services?
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#2265910 - 02/07/22 03:36 PM Re: CRA BOOK Amy S
M Cockrell Offline
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M Cockrell
Joined: Jan 2003
Posts: 1,033
Dallas, TX
If you're referring to "A list of services (including hours of operation, available loan and deposit products, and transaction fees) generally offered at the bank's branches and descriptions of material differences in the availability or cost of services at particular branches, if any" noted in 12 CFR 228.43(a)(5), it does not have to be specific to each/every product service offered. It would seem providing general info is acceptable. For example, what type of loans (mortgage, vehicle, personal, etc.), what types of deposit products (checking, savings, money markets, CDs, etc.), and what fees are associated (e.g., monthly/quarterly service charges).

That having been said, there's no prohibition against furnishing more information than required.
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#2265941 - 02/07/22 07:20 PM Re: CRA BOOK Amy S
Amy S Offline
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Joined: Sep 2020
Posts: 139
To clarify, it is copies of the new account disclosures per account type. This would be in additions to the list of services.

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#2265942 - 02/07/22 07:37 PM Re: CRA BOOK Amy S
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,651
Galveston, TX
If that is what you are using to disclose your costs of services, then it would have to be included. It is hard to say depending on what is in your "new account disclosure" compared to what is already in your public CRA file.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2265945 - 02/07/22 08:01 PM Re: CRA BOOK Amy S
Amy S Offline
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Joined: Sep 2020
Posts: 139
I'm thinking we can leave them out. Thank you for your input!

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