Disclosures given at account opening are not sufficient if the customer later signs up with the bank for an EFT service. The disclosures for the service must be given "proximate to" the time of signing up. The "disclosures at account opening" scenario only works if the customer is signing up with a third-party EFT service provider (such as signing up for direct deposit), and then only if the bank has not changed the terms affecting that service (direct deposit in this example) since the earlier disclosures were given. See Comment #1 to section 205.7(a) of the regulation in the OSC.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8