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#70920 - 03/31/03 10:39 PM Fee Schedule - Safe Deposit Fees
CalifDreamin Online
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CalifDreamin
Joined: Mar 2002
Posts: 2,237
Far from Calif
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.
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#70921 - 03/31/03 10:48 PM Re: Fee Schedule - Safe Deposit Fees
Anonymous
Unregistered

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

SusanL (I didn't sign in)

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#70922 - 03/31/03 11:26 PM Re: Fee Schedule - Safe Deposit Fees
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,794
Cape Cod
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.
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#70923 - 03/31/03 11:29 PM Re: Fee Schedule - Safe Deposit Fees
CalifDreamin Online
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CalifDreamin
Joined: Mar 2002
Posts: 2,237
Far from Calif
Thank you!
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#70924 - 04/01/03 01:23 PM Re: Fee Schedule - Safe Deposit Fees
E.E.G.B Offline
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E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Don't forget to include "There will be an extra charge if you store packages with visible wires or audible ticking...."
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#70925 - 01/16/04 06:16 PM Re: Fee Schedule - Safe Deposit Fees
michellecc Offline
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michellecc
Joined: Sep 2003
Posts: 128
Southern New England
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.

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#70926 - 01/16/04 07:55 PM Re: Fee Schedule - Safe Deposit Fees
AMXSteve Offline
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Joined: Jun 2001
Posts: 75
Wilmington, OH, USA
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.
Last edited by SteveMc; 01/16/04 07:57 PM.
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#70927 - 01/17/04 09:01 PM Re: Fee Schedule - Safe Deposit Fees
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
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.
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