Health Savings Accounts

Are HSA account subject to Reg DD disclosure requirements?
thank you

Yes, similar to IRAs held in consumer deposit accounts.

Section 230.2 Definitions
(a) Account
1. Covered accounts. Examples of accounts subject to the regulation are:

i. Interest-bearing and noninterest-bearing accounts
ii. Deposit accounts opened as a condition of obtaining a credit card
iii. Accounts denominated in a foreign currency
iv. Individual retirement accounts (IRAs) and simplified employee pension (SEP) accounts
v. Payable on death (POD) or ``Totten trust'' accounts

We are going to offer debit cards on our HSA accounts, and were told that Reg E disclosures were still not required, due the nature of the HSA. Is this right?

Bump. Anyone?

What we have been told is to make sure that the Reg E Error Resolution notices are not printed on the statements (or anywhere else, for that matter.) HSA's are not supposed to fall under Reg E.

Even if the Bank is issuing debit cards on these accounts? What if someone has their debit card stolen and their HSA account is wiped out? The customer doesn't have any rights?

Not under Regulation E, but if it a VISA/MC card, you are going to have to look at your VISA/MC contract to find out how they treat these.