Is it acceptable to place a statement message on bank statements directing our customers to our website for a copy of the new fee schedule or to contact the bank if they need a paper copy mailed to them or do we have to include the new fee schedule in the statement?
Posted By: BrianC
Re: Fee Change Stmt Message - 08/20/21 01:56 AM
If you are changing fees required to be disclosed on the TISA, it is not acceptable. The statement message must identify what fee is changing. If you do not have sufficient space to update all the applicable fees that are changing, then you must include a statement insert with the fees that are changing highlighted in some way along with a legend to allow the customers to identify which fees are changing.
For customers that receive E-Statement who have also provided consent to receive disclosures electronically, you can provide the statement message or updated schedule through that format.
See the commentary to 1030.5(a)
(a)(1) Advance notice required.
1. Form of notice. Institutions may provide a change-in-term notice on or with a periodic statement or in another mailing. If an institution provides notice through revised account disclosures, the changed term must be highlighted in some manner. For example, institutions may note that a particular fee has been changed (also specifying the new amount) or use an accompanying letter that refers to the changed term.
2. Effective date. An example of language for disclosing the effective date of a change is “As of November 21, 1994.â€
Examples of acceptable statement messages are included in Reg DD Appendix B
B-2--Model Clauses for Change in Terms
On (date), the cost of (type of fee) will increase to $----.
On (date), the interest rate on your account will decrease to ----% with an annual percentage yield of ----%.
On (date), the minimum [daily balance/average daily balance] required to avoid imposition of a fee will increase to $----.
If you are changing fees for ancillary services not connected to the account such as wire fees, cashier's check fees, or check printing fees, then Reg DD does not require notice.