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TIS notices for existing account changes

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  • #13881
    kmeade
    Participant

    Per Regulation DD – Truth-in-Savings, if a checking account has a tiered-rate feature (different rates apply to specified balance levels), if new balance levels are added to the account product (not a money market) are we required to send a notice to existing account holders? The new balance levels will be above the existing balance levels, so this change would be in the customers favor.

    #13884
    rcooper
    Member

    Even though you state it will be a beneficial change to the customer, I would recommend providing 30 days advance notice for changing the tier structure. While you might not be cited for not providing the notice 30 days in advance, I think you could avoid potential questioning by an examiner (who thinks you should have) if you go ahead and do the advance notice.

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