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#1696768 - 05/08/12 01:40 PM Truth in Savings Fees
Compl101TX Offline
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Compl101TX
Joined: Aug 2010
Posts: 378
W. TX
We are in the process of changing to a different deposits system, so the disclosures are changing.

While reviewing the Truth in Savings disclosure for different accounts I found that some disclose fees and others don’t. We have a separate disclosure for limits and fees. Could we have a reference in the TIS to the other “fees” disclosure? All fees apply to those accounts.

If so, where in the regulation or the commentary can I found something to back me up in case auditors want to write us up?
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AVP-Compliance

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Deposits and Payments
#1696821 - 05/08/12 02:32 PM Re: Truth in Savings Fees Compl101TX
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
That's very typical and has been done that way everywhere I've been. I.e., "Please see Common Fees Disclosure", then list any fees, etc., specific to the actual account. I've never had an examiner question it.
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#1697016 - 05/08/12 06:04 PM Re: Truth in Savings Fees Compl101TX
Compl101TX Offline
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Compl101TX
Joined: Aug 2010
Posts: 378
W. TX
Thanks RR Joker.
We will do that and save us future problems.
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AVP-Compliance

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