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Notification for New Monthly Fee (Checking Acct.)

Question: 
We are making changes to a checking account that we offer, we are going to implement a monthly fee. Because this will negatively impact our members, don't we have to notify them and how much time do we need to provide before making the change?
Answer: 

by Randy Carey:

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.

Answer: 

by John Burnett:

Since you mentioned "members," I'll assume that you're at a credit union. Your citation will be to section 12 CFR Part 707, section 707.5, which is substantively identical to the text Randy has quoted, with "members" substituted for "consumers."

First published on 01/13/2019

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