Outdated EFT Disclosure

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Question:

If a bank offers an existing customer an outdated EFT disclosure (with incorrect POS dollar limitations) upon applying for a new service (debit card) are they in compliance as long as it doesn't adversely affect the customer (the limit is actually higher than disclosed)?

Answer:

Your disclosure must be accurate. Overkill (the limit is higher than actually disclosed) does not make it correct. Your disclosures should "say what you do" and you should "do what you say".

First published on BankersOnline.com 6/11/07