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Notice 45 Days in Advance for Fee Changes?

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Question: 
We are currently in the process of changing our fees. Some fees may increase and some fees may decrease. With that said do we still need to send a notice to customers 45 days in advance of the changes?
Answer: 

If you are referring to deposit accounts.

1030.5 Subsequent disclosures.

(a) Change in terms. (1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under Sec. 1030.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer. The notice shall include the effective date of the change. The notice shall be mailed or delivered at least 30 calendar days before the effective date of the change.

First published on 12/01/2019

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