Discontinuing Bank Products

Posted By: corporate audit

Discontinuing Bank Products - 01/28/16 08:52 PM

Are there any laws/regulations or guidance regarding discontinuing bank products and moving customers into other products that may not be as advantageous to them? Of course, a Change in Terms Notice is required. But is there any other guidance that would address this like there is for closing branches?

Thanks in advance.
Posted By: rlcarey

Re: Discontinuing Bank Products - 01/29/16 01:45 AM

Depends on the product and how much you want to [censored]-off those customers and possibly be accused of a UDAAP by the regulators.
There are a lot of issues to deal with that are not black and white in a regulation.
Posted By: Richard Insley

Re: Discontinuing Bank Products - 01/29/16 03:17 AM

If "bank products" includes HELOCs, isn't it still the case that Regulation Z generally prohibits changes in terms?
Posted By: rlcarey

Re: Discontinuing Bank Products - 01/29/16 12:23 PM

Yes. That is why the first thing I mentioned was products, HELOCs, credit cards, etc. would present unique challenges. smile
Posted By: corporate audit

Re: Discontinuing Bank Products - 02/08/16 10:24 PM

The products referred to are deposit products. Thanks for your comments.
Posted By: Elwood P. Dowd

Re: Discontinuing Bank Products - 02/10/16 10:31 AM

There is no "how to" list or regulation focused on the issue. If your bank has a "products" committee, the task would be on their plate. The easiest points to focus on would be changes to those which you were required to disclose under Regulation DD, but you should think more broadly.

If you are thinking about changing terms on time deposits, that can only be done as they mature and in accordance with Regulation DD.
Posted By: GenerousLife

Re: Discontinuing Bank Products - 03/02/16 07:44 PM

As part of product development, you should have an Exit plan in place prior to rolling out new products. Eventually, when the life cycle of that product/service expires, you will have guidance from your own research in the beginning, using those regs that apply to the product itself.

When you are able to think about this as you develop a product, it does sometimes change your product. No one likes to do this part, but it will pay off in the future.
Posted By: Rocky P

Re: Discontinuing Bank Products - 03/03/16 02:06 AM

As part of product development, you should have an Exit plan in place prior to rolling out new products. Eventually, when the life cycle of that product/service expires, you will have guidance from your own research in the beginning, using those regs that apply to the product itself.

Take a look at OCC Bulletin 2004-20 Risk Management of New Expanded or Modified Bank Products and Services. It discusses how to evaluate, etc.