Commercial Deposit Account Disclosures

Posted By: ComplianceGurl, CRCM

Commercial Deposit Account Disclosures - 01/05/18 07:45 PM

Although not required, we have always included a TIS section in our commercial account disclosures. We are thinking about removing that from our disclosures because our system does not allow us to modify fee descriptions. Just curious if anyone else provides it or doesn't? Pros vs cons?
Thank you in advance for your feedback.
Posted By: rlcarey

Re: Commercial Deposit Account Disclosures - 01/05/18 08:46 PM

How do you have a contract for fees without including them in your agreement?
Posted By: ComplianceGurl, CRCM

Re: Commercial Deposit Account Disclosures - 01/09/18 05:05 PM

That's a great question and what I'm wondering. We are going through a system upgrade, including new forms. We were asked if we wanted TIS included in our business disclosures which got me thinking (not always a good thing). As I did more research I read several times that TIS is not necessary for business accounts. It's not that we don't want to include it but we were told during a recent audit that our fee descriptions on marketing information, disclosures and statements must all match exactly. It's not a problem for our consumer accounts but for business accounts we don't have the option of modifying the description. It's just a very generic term of Cycle Service Charge. Also, if there is more than one fee charged, the fees are all lumped together on the statements with that description. I questioned our auditors that TIS only applies to consumer accounts and they came back with a potential UDAAP issue on the business side if they don't match.

I'm sure this is way more that you cared to hear about but I was just thinking that by not including a TIS we would eliminate the whole problem.