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#2270067 - 05/04/22 08:55 PM Fee change - acquisition
Comprunx3 Offline
Member
Joined: Oct 2015
Posts: 86
If a new fee schedule (etc) is provided to consumers in advance of a FI acquisition is there a requirement to highlight the specific fees that will be higher than the acquired FI had or is the delivery of a new fee schedule sufficient.

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#2270087 - 05/05/22 03:45 PM Re: Fee change - acquisition Comprunx3
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
What do you mean in advance of an acquisition?
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#2270101 - 05/05/22 05:47 PM Re: Fee change - acquisition rlcarey
Comprunx3 Offline
Member
Joined: Oct 2015
Posts: 86
In advance - ahead of the acquisition date when we provide membership disclosures and fee schedule etc.

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#2270105 - 05/05/22 06:13 PM Re: Fee change - acquisition Comprunx3
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,716
Illinois
If you are providing a new disclosure, the adverse changes must be highlighted. See the commentary to 1030.5(a)

1. Form of notice. Institutions may provide a change-in-term notice on or with a periodic statement or in another mailing. If an institution provides notice through revised account disclosures, the changed term must be highlighted in some manner. For example, institutions may note that a particular fee has been changed (also specifying the new amount) or use an accompanying letter that refers to the changed term.
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