TISA Reg CC Disclosure for Account Inquiries

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Question:

I recently went to a seminar and during it they mentioned that we should issue a TISA and Reg CC disclosure to any potential customer inquiring about our accounts regardless if they open an account or not. Is it a violation if that is not done and they are only issued to customers opening accounts?

Answer:

Answer by Brian Crow: Yes, it is a violation.
Reg DD 1030.4(2) requires that a Truth in Savings disclosure be given to a customer who asks for information about an account. If the request is made via the phone or internet, within 10 business the institution must mail the disclosures or provide them electronically if the customer agrees.

Reg CC 229.18 requires that you provide your funds availability disclosure upon request to anyone who requests one whether orally or in writing.

Many institutions incorporate these disclosure into their account brochures that can easily be handed out to reduce the risk of non-compliance.

Answer:

Answer by John Burnett: To qualify Brian's response just a bit, you don't have to consider an inquiry in to deposit rates an inquiry triggering the need for disclosures. And if someone asks about your bank's checking accounts, you don't need to send information on savings or time deposit accounts.

First published on BankersOnline.com 2/25/13