Could changing a statement cycle date be considered having adverse impact on a customer? The only situation of concern is due to our service charges hit on the statement cut date. This will change the timing of this fee, as much as a week before or after the previous statement date. Does anyone think this would require the 30 day notification?

A few years ago, our institution consolidated Money Market Statement cycles and we provided the DD 30-day notification.

We provided notification via a statement message similar to- "Effective xxx, all personal money market accounts statement printing dates will be consolidated to the 15th of each month. Any questions, please contact xxx for assistance."

For service charges, the fee timing issue was resolved by suppressing the service charge assessment until the next truly "full" statement for each customer. Interest assessment was the same, the accrued interest was not "paid" and the interest accrued amount was paid on the next full statement for each customer.

I forgot to mention, we actually gave longer than 30-day notification to ensure all accounts affected received at least 30-day notification.

Depending on the dates, some accounts would actually have more notice, but all received at least 30 day notification.