Since remittances are now (or will be) brought in under Reg E, should anything be added to the current Reg E disclosure that is provided to customers at account opening? A "Change in Terms" notice required since new products are now available and protected under Reg E? Should the Error Resolution Notice sent to consumers be updated to reflect the Remittance error resolution process? Online banking agreements updated?
Also, if we change our wire fees (that we list on our Fee Schedule) - would that require a change in terms under Reg DD?
Or am I way off base and need to be looking at this process as a new product/service being offered and disclosures are only required at the time the remittance is ordered/transacted?
Any help will be appreciated. I am only confusing myself!!