Truth in Savings - 03/23/01 09:22 PM
Assume the following scenario: Ken and Kathy Sally are interested in learning about the bank's available checking or savings products. They are not yet ready to open an account, but they request an account disclosure for review. Am I correct in saying that the disclosure must generally be the same as the disclosure that would be provided if they were actually opening an account of the same type? Must that pre-opening disclosure meet the requirements of 230.4(b) or 230.8(c)? Also, what if the new accounts rep. gives them a printout of a screen from the bank's website for informational purposes, but the consumers did not specifically ask for any disclosure?
Would that be permissible? In this case, the website advertising disclosure would meet the conditions of 230.8 but not 230.4.
Thanks for your responses.