Combined Account Opening Disclosures

We are looking into combining a lot of our deposit account opening disclosures into a single booklet. All the deposit account (checking, savings, money market)disclosures will be combined together in one section. The combined disclosures won't list a rate or effective date to keep us from having to make a new book each time rates change. A seperate interest rate sheet will be put in the book and changed when rates move. The booklet disclosure will instruct the consumer to "see attached rate sheet". I'm worried doing like this might not be clear and conspicuous. Does anyone else have a system like this?

Reg DD requirements are below: General Requirements (§230.3(a) and (b)) Section 230.3 outlines the general requirements for account disclosures and periodic statement disclosures.
Such disclosures are required to be
• Clear and conspicuous;
• In writing;
• In a form the consumer may keep;
• Clearly identifiable for different accounts, if
disclosures for different accounts are combined;
• Reflective of the terms of the legal obligation of
the account agreement between the consumer
and the depository institution;
• Available in English upon request if the disclosures
are made in languages other than English;
and
• Consistent in terminology when describing terms
or features that are required to be disclosed.

Banks use a separate rate sheet all the time.


I would be much more concerned about this. Are there going to be check boxes or something that indicates which distinct disclosures apply for the specific account or accounts the consumer sitting in front of you is opening??

Clearly identifiable for different accounts, if disclosures for different accounts are combined

Will the "booklet" be manually marked for the applicable disclosures? Disclosures coming off a system have boxes checked or, alternatively, just provide the applicable disclosures. That will be more difficult in a hard copy booklet, unless this "booklet" will be printed with each account.