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#2068375 - 03/10/16 02:39 PM Account Conversion
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
We are eliminating some outdated deposit products and converting these customers to our standard products. The changes to the accounts are minimal, if any othr than what the account type is called. My question is must we send complete new disclosures or can we send a letter stating what the changes are?
Last edited by Want2komply; 03/10/16 02:41 PM.
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#2068429 - 03/10/16 04:30 PM Re: Account Conversion Banker57
Renea Rush Offline
Member
Joined: Dec 2011
Posts: 74
When we did this, we sent a letter 30 days before the change with a table showing changes - because there were things changing. We also included a new TISA disclosure.

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#2068549 - 03/10/16 09:14 PM Re: Account Conversion Banker57
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
We followed the procedures described by rrush.

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#2068556 - 03/10/16 09:28 PM Re: Account Conversion Banker57
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
Thank you!

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#2068679 - 03/11/16 05:23 PM Re: Account Conversion Banker57
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no uniform answer. If any change involves something that is required to be in a TISA disclosure, then you follow TISA's rules. You would make the decision one account type at a time.
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