We have had several customers that have contacted the bank recently to request that they change account types. If a customer requests to switch account types from say an interest-bearing account with a monthly fee to a noninterest bearing account with no fee, we don't close the account in our core. We simply switch the account type on the existing account, and we provide a new Truth in Savings disclosure for the type of account that they switched to. The question has come up that if our Truth in Savings disclosures don’t disclose that any accrued but uncredited interest will be forfeited upon closing an account, do we have to credit that accrued but uncredited interest if the customer requests the account type change? Would it matter if we disclose at the time of the requested switch that they are forfeiting that interest?

If you are not disclosing the loss of accrued interest at the time of account closure or the switching of products, I would be paying it.

That's what I thought.