Effective 9-1-02 we are changing some general fees such as research fees, photocopying, cashier's check fees, etc. We plan to notify all checking and savings customers which will be easy with a statement stuffer. However, some of these fees could affect a CD only customer - so do they have to be notified? Since CD only customers do not receive a statement, we will have to make a separate mailing to them.

If that fee can effect them and is adverse, they should be notified unless you impose some program whereby they are not effected.

That is, you don't notify them (and save a ton of postage) and don't impose the higher fee if that is the only product type they have with you (which could cost a pound of lost income).

If the CD customer also has a DDA or Savings with you, they'll be notified.

Your research fees are subject to disclosure under §230.4(b)(4) if they apply to CD accounts. Accordingly, if you "up" those fees, and intend to apply them to your current CD accounts, you'll want to notify them.

Photocopying and cashier's check fees, however, are charged to customers and non-customers alike, aren't they? If so, these fees are not subject to disclosure under §230.4(b)(4) and you would not need to provide 30-day notice of those changes.

Could you mail this change with your privacy notices? They have to go to everyone anyway.

You may combine in a single envelope a Reg. DD notice of change in terms and your Reg. P annual notice.