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#26238 - 07/31/02 10:48 PM Monthly Bill Pay Fee
Kahola Offline
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Kahola
Joined: May 2001
Posts: 712
Scottsdale, AZ. 85255
If we disclose on line the fee for monthly bill pay do we need to include this fee in our disclosures for Reg DD when opening a new account at a branch?

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eBanking / Technology
#26239 - 08/01/02 01:04 PM Re: Monthly Bill Pay Fee
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Do you have to? No. Bill pay is not an integral feature of any account, since customers apply for this service à la carte.

Should you? Your call.

What you do have to do is make certain each of your customers applying for bill pay service gets the disclosure of your fee. It's a Regulation E disclosure.
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John S. Burnett
BankersOnline.com
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#26240 - 08/01/02 01:46 PM Re: Monthly Bill Pay Fee
Andy_Z Online
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Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
I wouldn't simply because this is an elective product that a minority of customers will use. You could also open yourself up to change in terms notices later to the universe of customers instead of the users, or at best needless disclosure modifications.

You'll disclose this cost prior to enrollment into the product anyway, so it will be covered more timely and with an interested audience.
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AndyZ CRCM
My opinions are not necessarily my employers.
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