Regulation DD-Subsequent Notice

I would appreciate any assistance with interpreting the commentary to 12 CFR 230.5(a(1)regarding subsequent disclosures-change in terms. Basically, I need to know if the 30 day advance notice is required. We are considering a youth savings account with no service charge until 18 years of age. Once the minor turns 18 (terms change upon the occurrence of an event) we will start charging a maintenance fee. Our account opening disclosures will fully describe the conditions; however, the system is not set up to send out an advance notice. Thank you!

If you go to the commentary of 230(5)(a)(1), it will tell you that you do not need to send a subsequent notice because you fully explained the change at account opening.


3. Terms that change upon the occurrence of an event. An institution offering terms that will automatically change upon the occurrence of a stated event need not send an advance notice of the change provided the institution fully describes the conditions of the change in the account opening disclosures (and sends any change-in-term notices regardless of whether the changed term affects that consumer's account at that time).

Ditto Randy (he beat me to it). And while that could be a very long time before the change kicks in, that would seem to be alright, though a notice would be good customer service.

§230.5 Subsequent disclosures.
4. Examples. Examples of changes not requiring an advance change-in-terms notice are:

i. The termination of employment for consumers for whom account maintenance or activity fees were waived during their employment by the depository institution

I would use this as an example demonstrating your scenario.

In other words, in the initial disclosure spell out all of the details (including the fees that will be charged when they turn 18). If this is done, Reg DD says you have already told them so there is no change in the terms.