Providing Account Disclosures

Posted By: corporate audit

Providing Account Disclosures - 01/26/21 03:47 PM

Are initial disclosures required to be provided when a new account is opened for a customer due to an account takeover due to fraud?
Posted By: BrianC

Re: Providing Account Disclosures - 01/26/21 03:58 PM

It's a new account. Yes.

1030.4(a) Delivery of account disclosures. (1) Account opening. (i) General. A depository institution shall provide account disclosures to a consumer before an account is opened or a service is provided, whichever is earlier.
Posted By: corporate audit

Re: Providing Account Disclosures - 02/01/21 02:12 PM

So even if it is the same type of account the initial disclosures are required?
Posted By: rlcarey

Re: Providing Account Disclosures - 02/01/21 02:19 PM

Define opening an account. You mean you are just assigning them a new account number? If that is the case, then I would not get too concerned over it as long as you are sure that they have received proper disclosures previously.