For Reg DD disclosure purposes, what is the account opening date? I can't find this clearly defined within Reg DD. Ideally, the account application is completed and funding happen the same day, but customers found the means to complete the application, but fund later. I'm wanting to get my disclosures out accurate and timely.

Reg CC does define account opening as the day a funding deposit is made so I lean that way, but prefer explicit instruction when I can get it.

Thanks in advance.

Nudge, nudge?

A depository institution shall provide account disclosures to a consumer before an account is opened or a service is provided, whichever is earlier. An institution is deemed to have provided a service when a fee required to be disclosed is assessed.

How can they possibly fund an account if it not open?

I just opened a new account with a large, mostly online bank. I was told upfront that the account would not be opened until I funded it (there were several ways to accomplish that), and it would be closed and purged it was not opened within 30 days. Apparently, the account sat on the books as "pending open" for three days until my wire transfer arrived. It's a one-year CD, and the maturity date is one year from the date the funds hit the account.