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#2057821 - 01/11/16 05:39 PM monthly statements
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
We are looking to discontinue use of preprinted statement paper. The back of the preprinted paper includes the Error Resolution disclosure, among other items. Does any one else use plain paper and have a way to include the monthly disclosure information without printing and stuffing a separate sheet of paper? Our core processor says that they do not have the ability to attach this information to the last page of each individual statement. We are looking into other alternatives to make this process more cost effective. Thank you for any help or thoughts.

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eBanking / Technology
#2057967 - 01/12/16 01:21 PM Re: monthly statements Banker57
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,355
Galveston, TX
Do a separate mailing or insert only once a year.

(b) Error resolution notice. For accounts to or from which electronic fund transfers can be made, a financial institution shall mail or deliver to the consumer, at least once each calendar year, an error resolution notice substantially similar to the model form set forth in Appendix A of this part (Model Form A-3).
1005.8
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2058153 - 01/12/16 07:31 PM Re: monthly statements Banker57
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
That was my initial thought as well. In addition to the short EFT disclosure our statement paper includes a section on: 'Your demand deposit loan account summary of rights is outlined below' and a section titled 'In case of errors or questions about your demand deposit loan or home equity line of credit' Are these areas required on a monthly basis or can this be included in the annual mailing as well?

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#2058159 - 01/12/16 07:39 PM Re: monthly statements Banker57
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,355
Galveston, TX
Refer to 1026.9(a) and (b)
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2058181 - 01/12/16 08:16 PM Re: monthly statements Banker57
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
Thank you! I have the 2 figured out, I just need to figure out the DDL part.

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#2058187 - 01/12/16 08:23 PM Re: monthly statements Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 85,355
Galveston, TX
'Your demand deposit loan account summary of rights is outlined below'

What does this say?? I would have no idea if it was not the billing errors notice.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2058270 - 01/13/16 02:21 AM Re: monthly statements Banker57
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,231
Toano, VA
Originally Posted By Want2komply
Are these areas required on a monthly basis or can this be included in the annual mailing as well?
In order to determine the adequacy of you language and delivery method, you need to identify what authority (if any) governs these notices. That could be federal regs (of which I have no recollection), state or local law/regulation/ordinance, or your internal policy. If policy is the only thing requiring these notices, then you should determine who was your policy maker and go sit down with that person and ask for an explanation of this self-imposed requirement.
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...gone fishing.

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