We are in the process of updating our disclosures for 7/1/06.
We do not offer or advertise ODP. We have distinguished what and OD and an NSF is. The question is....currently we do not disclose these items in the initial TIS disclosure. All fees are disclosed in the fee schedule which they get with the initial disclosures. Is this adequate, or do we need to add it to the TIS disclosure as well? We do have a paragraph in the TIS disclosure that states they need to see the Service Fee disclosure for any fees they may be charged.
My opinion is mine only- not my employer's!