Our forms provider recently changed the wording in 3 or 4 areas in our deposit forms. They are indicating that we need to send all our customers the 30 day notice and I agree with this and since we are making some other minor changes, needed to send them out anyway. BUT, they are recommending we send out the whole four page disclosure, and the only place it says anything about it being a change of terms in the account agreement is at the very top of the first page.

I read the reg to say that if an institution provides notice through revised account disclosures, the changed term must be highlighted in some manner. I don't think putting a note on the top of the first page of the disclosure satisfyies this . . . since this is a popular provider, I'm sure the rest of you considerreed this. Did you agree to their recommendation?

I also think that what isn't covered under Reg DD might be basically contract law and by not highlighting them would be a concern under UDAAP.

Thanks.
Last edited by biz; 02/24/14 01:43 PM.