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#626517 - 10/19/06 02:14 PM Change in Account
Tocomply Offline
Platinum Poster
Joined: Nov 2004
Posts: 650
When you make a change to an account and you notify the customer do you need to send disclosures? We are re-naming the account and in the notification we want to inform the customer of the current rate. If we state the APY what do we need to disclose?

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Operations Compliance
#626518 - 10/19/06 02:41 PM Re: Change in Account
maryinutopia Offline
New Poster
maryinutopia
Joined: Mar 2006
Posts: 19
Kentucky
If you make an adverse change to an account, you must send the disclosure of such a change actually 60 days in advance of the change. If you're just changing the name of the account(and that is the only change), you could send notice but it doesn't require disclosures.

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#626519 - 10/19/06 02:51 PM Re: Change in Account
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
Regulation DD requires a 30 day advance notice for adverse changes, not a 60 day.
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#626520 - 10/19/06 03:50 PM Re: Change in Account
Tocomply Offline
Platinum Poster
Joined: Nov 2004
Posts: 650
Ok. Our letter states the title change, reason then indicates that the current APY on this account is ......
Would you consider this advertising? Our legal group seems to think it is.

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