On our fee schedule, can we simply say, "varies by size" for the safe deposit box fees, then use a separate fee disclosure specifically outlining safe deposit box fees if someone inquires about them? I think we have to list them all on the "main" fee schedule, but I want to be sure before I say no to the "new and improved" idea.

I see in Reg. DD commentary for 230.4 where it discusses fees that must be disclosed, but I don't see safe deposit boxes listed specifically.

Our fee schedule also says varies by size, but we also state $15.00 and up (annually).

SusanL (I didn't sign in)

Reg DD really doesn't care what your safe deposit box fees are. It only requires disclosure of fees related to the account on which you are making disclosures.

If you wish to include a reference to your safe deposit fees in the schedule you hand out with new account disclosure "bundles," the way you're doing it now sounds just fine to me.

Thank you!

Don't forget to include "There will be an extra charge if you store packages with visible wires or audible ticking...."

John, Does this mean we don't have to abide by the 30-day notice (Reg DD) if we increase our safe box fees even though it adversely affects the customer? Is there a time limit we need to notify the customer of increases in safe box fees? Thanks.

I don't think that you have to mention safe deposit boxes at all on your main fee schedule. As for changes in the annual rent, check your safe deposit box lease. Our lease (a Bankers Systems form) states that we will post any increases in rent in our safe deposit box area at least 30 days before they take effect. Safe deposit boxes are governed more by contract than regulation.

Michelle,
Yes. As John notes, Reg DD only requires disclosure of fees "in connection with an account;" it does not affect the disclosure or alteration of fees on unrelated services. As Steve notes, if you you have made a promise to provide notice in your lease or contract that controls; i.e. you would have to comply with it. Otherwise, it's a matter of courtesy or state law.