I would not combine them. One is account-oriented; the other is transaction oriented. The subpart A disclosure has to be provided at account opening and then either annually or with each periodic statement; the subpart B disclosure has to be available upon request to a Sender, who need not be a Depositor. The two disclosures have nothing in common.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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