We are changing several terms for our deposit products. We will be providing advanced notice to all customers. The issue we're running into is how to provide notice to customers receiving e-statements. Our software only allows us to have one statement backer at a time for all account types. Unfortunately, many of our accounts are on the same statement cycle so we would need to either include the changes for all applicable accounts on one page or figure out another solution. I would rather not include everything on one page when only a small portion would be relevant to each customer. I believe that could easily result in unnecessary confusion.
One possible workaround is including the change in terms on our bank's website and having a statement message sent informing the customer that there has been a change in terms and to click here for details. Would that workaround be compliant with Reg DD?
It should be noted that this would be for customers who have consented to receive e-statements. I still need to verify if our ESIGN agreement allows for this or not, but assuming it does, could we issue the change in terms notice via a one-click link?