If we disclose in our TIS that an account has a $750.00 minimum amount required to open the account, can we make an exception by allowing a customer to open the account with only $50.00?

I am going to defer to one of the more knowledgeable compliance types to back me up on this, but I BELIEVE you can do things like that so long as it's in the customers favor. What I'm saying is that you could let them open the account with $50 (as it is in the customer's favor), but not with $800 (or any other amount over $750). If you are going to do this on a consistent basis, though, I'd suggest changing your TIS disclosure.

teresa,
I don't think making an exception is a regulatory problem - so long as it does not become the rule rather than the exception. If the account has service charges for amounts under $750, you need to be sure your customer understands that. Additionally, why do you want to make the exception? Is the balance of $700 to follow shortly? My Security Department tells me that most of the fraudulent accounts we see are opened for small dollar amounts - often in violation of policy. Just a consideration.
Leslie

While it would strike me as odd to go from $750 to $50, I think you could do it. But I would be careful to denote any fees that may be charged automatically because of the low balance and I think I'd want some CYA memo explaining why the change or exception was allowed.

Once you have pen & ink changes to your disclosures and policy exceptions approved, you run a real risk violating terms of your contracts and disclosures.

A sole proprietor (already a customer) came to the bank to open a NOW account. He only had $50, but planned to make another deposit in a few days to bring it to the $750 level, which is required for no service charge and interest to be paid. He was quite miffed when we would not accept less than $750 to open the account and walked down the street to another bank and proceeded to open the account. I can understand the customer service issue in opening the account. But, Reg DD requires the disclosure of the minimum amount to open the account. I just wanted to make sure there would be no problem in the future if we accept an opening deposit for less than what we have stated in our disclosure.

Thanks for the advice.

If the sole proprietor's NOW account was to be for business purposes, Reg. DD would not have applied and you could do whatever the bank wanted without a violation of the regulation.

Exceptions to retain business for consumer accounts would not cause a problem, either, as long as you did all the things recommended above, and didn't make it a practice.