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Change in terms notifications via the Internet

Question: 
Is it possible to provide notice to our customers of a change in the terms of our deposit product line by posting the new account disclosure on our website? We currently have our existing account disclosures available on the bank’s website.
Answer: 

Regulation DD requires advance notice of any change in a term that is required to be disclosed. The bank cannot be sure that all affected consumers will go to the website and see the information at least 30 calendar days prior to the effective date of the changes. In addition, the bank cannot be sure that all affected customers have access to a computer to receive the required notice. Therefore, posting a notice of changes on your website is not an effective method of notification.

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Learn more about Nancy Derr-Castiglione’s webinar Change in Terms – Regulatory Issues for Deposit and Loan Accounts

First published on 11/15/2020

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