Suppose a customer wants to change from a club checking account that is charging a flat-fee of $x per month to a free checking account? Realizing that a new TIS needs to be given to the customer because there is now a change in the free (as well as now the customer will not earn interest in their free checking account), is there a time requirement when this needs to be given to the customer?

Assuming the change can be done file maintenance request form per the customer's authorization, does the TIS need to be given at that moment the customer asks for the change, or can it be mailed after the change is made on the system? Likely the Teller that speaks with the customer will not have FM change capability and this will need to go to a manager or administrative person to make the change.

I'm wondering if this is similar to the 3-day disclosure requirement on the lending side. Thanks for your help...

Eric

Disclosure must be made at the time the account is opened or service is provided when the consumer is present. When the consumer is not present, the bank has 10 business days from the date an account is opened or serivce provided to provide a written notice. Our tellers don't handle changes of this nature. Our tellers have a customer service representative handle the customers product change request -- this allows the CSR to make sure the consumer is getting most appropriate product for his/her needs and they can then provide the appropriate disclosure if the product is changed.