we require current customers to come into the bank to change the type of bank account they have (e.g. go from a NOW to a Rewards)- I think the rationale was that way we could give out all disclosures.

We are seriously considering allowing existing customers to call in and switch -

Does anyone see any serious compliance issues with this - assuming that we mail the disclosures to the customer

Some questions for your to consider/risk assess before making this change:

How would you obtain a new signature card for the new account?

If the CIP (i.e. Driver's license) you have on record was expired/outdated, how would you obtain the proper CIP on the new account?

Can you positively ID your customer by phone to your satisfaction?

Is there a potential for fraud?

Is there a problem with the customer possibly performing transactions on the "new" account before they have received the disclosures? What if there's a fee that they are assessed before you've even disclosed the fee to them?

I'm not sure I'd be a fan of this idea. We'd have to think it through and risk assess it. We don't currently allow this.

For most of the questions/reasons that BurntSienna cited, we require the customer to come into the office. This not only allows us to get everything in order, but is also a good time to see how else we can help them.

Could you just change the type code for the customer and provide disclosures(or change the account type 30 days after providing disclosures)?

As they are current customers (as long as the account was not closed prior to the change) I would not see an issue with CIP.