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Temporary Servicing Disclosures for Loans and Depo

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Question: 
We have a very small subsidiary bank whose contract with its core systemes provider is not being renewed. The bank obviously needs a temporary core system until they close a new contract with another provider. One proposed solution is to onboard the small bank's 100 or so customers onto our core. We would manually process the small bank's transaction files from imported data, which our IT teams are handling. Bottom line, the small bank will retain its ABA#, but their debit cards will have to be reissued by us, the larger bank, and during the transition the cards will bear our name. My concern lies in disclosures and compliance. What disclosures do we as the larger, "host" bank need to provide to the smaller bank's customers while their accounts are serviced by us, on our system? The smaller bank is a digital-only bank.
Answer: 

You need a skilled consultant and probably legal counsel involved and not a one paragraph answer from a BOL participant.

First published on 04/16/2023

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