Skip to content
BOL Conferences
Thread Options
#1444271 - 09/16/10 07:22 PM Change in term notice
Wonderofitall Offline
100 Club
Wonderofitall
Joined: Sep 2010
Posts: 227
Out West
Unless an account agreement requires it, there is no Reg. E or Reg. DD notice required for a change in the order in which the bank pays checks is there?
_________________________
You're never too old to learn something stupid.

Return to Top
Deposits and Payments
#1444356 - 09/16/10 08:25 PM Re: Change in term notice Wonderofitall
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Since you restricted your question to Regulations E and DD, no.

However, I'm sure you're aware that the order of item payment is a hot button with regulators right now, and there are some guidance documents issued in 2005 and two proposals to supplement that guidance, all of which touch on the issue.

Depending on the bank's federal regulator, making a change to posting order without notice to customers could draw criticism from examiners under the wide-reaching UDAP umbrella. The OTS is particularly public about its concern.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  John Burnett