If we decide to attach a "perk package" to one of our existing checking accounts, do we need to change our Truth in Savings brochure to list those perks?

In other words, if we decide to offer fee ATM usage, or Free Money Orders or Cashier's Checks to a the holders of a certain account type, do I have to update the truth in savings to detail those perks? Or can I simply advertise the perks since they are benefits to account holder, not truely a change in terms.

Any help would be greatly appreciated.

Thanks!

As long as your "perk package" isn't a bonus under Reg DD, you shouldn't have to revise your disclosures.

You need to be careful that you do not mislead your customer. If the current disclosure references fees for services (such as ATM fees) and you are not going to be charging me those fees, you have not provided me with an accurate disclosure. As a consumer, I should be able to rely on the disclosure you provide to me. Shortcuts that confuse a customer can lead quickly to regulatory criticism.

If your current disclosure doesn't reference these fees (especially those not technically requiring disclosure under Reg DD), then waiving the fees shouldn't be an issue.

Our Truth in Savings disclosure doesn't talk about ATM fees, but the fees are listed in the Personal Schedule of Charges. Would I then have to update the Personal Schedule of Charges to show "Free" for this particular group?

ATM fees are not a required fee disclosure on a specific account unless you automatically include the ATM card with the account (which I have never seen). While I personally prefer disclosing whether ATM fees apply to each account, it is not a requirement. But I should be able to look at my specific account disclosure along with any other applicable disclosures (such as the ATM agreement if I requested an ATM card) and understand exactly what fees I will be subject to.