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Disclosures Required for OD Line of Credit Changes

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In 2006, we merged the three banks in our holding company into one bank. At that time we did not change our overdraft line of credit product. However, we want to make some changes to our overdraft protection line of credit product so that they are all consistent. Are we required to send a full set of disclosures or can we send a letter outlining the changes and include a statement such as "all other terms and conditions of your overdraft protection account remain in full force and effect"?

You should refer to 226.9 for change of terms requirements under Reg Z. You should have your attorney review all prior contracts to make sure that you cover all changes of terms in addition to any terms required to be disclosed under Reg Z. Sometimes it is just easier to send them all brand new contracts.

First published on 7/07/08

First published on 07/07/2008

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