Posted By: kburrows
Notification of Daily Overdraft Charge - 02/20/07 08:48 PM
When implementing a daily overdraft charge on consumer accounts, must the Truth In Savings/Terms and Conditions of Your Account be altered to include the fee, or can we notify consumers by another route?
Posted By: John Burnett
Re: Notification of Daily Overdraft Charge - 02/20/07 09:07 PM
Well, you need to provide prospective customers of the new fee, so whatever "bundle" of disclosures you provide at account opening will have to have it.
You can notify your existing consumer customers by any written means you wish to employ, except that if you want to do it electronically, the consumer must have already signed up for electronic disclosures, in an e-Sign compliant mode.
Posted By: kburrows
Re: Notification of Daily Overdraft Charge - 02/20/07 09:15 PM
Thanks, John. That makes sense.