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#544224 - 05/05/06 06:31 PM Incorrect disclosure
Floridian Offline
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Joined: Jul 2004
Posts: 56
We have discovered that our most recent deposit account disclosure has an error. The service charge for one type of account is $13, we disclosed as $15. Since this is in the customers favor, must we re-disclose or will we be OK with the regulators until the next printing? Thanks
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#544225 - 05/05/06 10:11 PM Re: Incorrect disclosure
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
IMHO - Yes
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#544226 - 05/08/06 12:30 PM Re: Incorrect disclosure
Floridian Offline
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Joined: Jul 2004
Posts: 56
Yes will we be OK to send or yes should we redisclose?
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#544227 - 05/08/06 01:09 PM Re: Incorrect disclosure
Gotwood Offline
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Joined: May 2001
Posts: 715
This is where you earn your money. Make a decision - is this a significant enough risk that you should spend additional monies to correct. IMHO - this can wait.

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#544228 - 05/08/06 01:39 PM Re: Incorrect disclosure
Floridian Offline
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Joined: Jul 2004
Posts: 56
I only asked for an opinion Gotwood....not a lecture on how I earn my money.
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#544229 - 05/08/06 01:46 PM Re: Incorrect disclosure
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Regulation DD doesn't provide a method for correcting an error. Even though it's in the customers' favor, I would send a written notice correcting the amount. (Is a statement message a possibility?)

You mention waiting until the next re-printing... I would say that's not an option on a "go forward" basis; i.e. you cannot continue to hand out a disclosure you know to be incorrect. You can put a sticker or an attachment on the disclosure that makes the correction.
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#544230 - 05/08/06 01:50 PM Re: Incorrect disclosure
Floridian Offline
Member
Joined: Jul 2004
Posts: 56
The disclosure is on a mailer going to a small number of potential customers in a certain area. It is advertising a certain product and the monthly fee was printed incorrectly. If the customer opens the advertised account the disclosure at account opening will be correct.

Thank you for your response.
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#544231 - 05/08/06 01:57 PM Re: Incorrect disclosure
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Then forget what I said before... If the promo I received is incorrect, but the disclosure I receive prior to opening the account is correct, then I believe the correct information was provided to the appropriate people.
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#544232 - 05/08/06 07:55 PM Re: Incorrect disclosure
FraudBuster Offline
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Joined: Nov 2005
Posts: 198
Indiana
Is there any way your Marketing Department can turn this into a selling point instead of an error? Like a sticker added to the mailer saying, "The deal just got even BETTER!!!"

Then, the innocent ones will be thinking, "Gee, this bank looks better all the time," while the cynical ones will be thinking, "It's an advertising ploy; they printed the wrong amount on purpose!" Either way, nobody's thinking, "Doesn't this bank know what its own fees are?"

I don't know why my bank keeps me in the fraud area instead of marketing . . .
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