Are new disclosures (Reg DD, CC. Depository Agreement, and Privacy Notice) required when a minor account converts to a regular account when the minor reaches age 18? The minor (now adult) may have never received a privacy notice or the account disclosures. Seems odd to share the now adult's PII for affiliate marketing without having provided a privacy notice to them.

If the minor was the account holder, why did they not get all of these disclosures when the account was opened? If the terms of the account are changing, then yes, new disclosures regarding the account will have to be provided according to the timeframes in Regulation DD for changing the terms.

If you previously disclosed that the minor account would convert to a regular account when the minor turned 18, disclosed all of the requirements of a regular account at that time, and disclosed any changes to terms to the regular account during the course of the minor account, then I do not believe Reg DD disclosures are required.

OFFICIAL INTERPRETATION OF SECTION
Section 1030.5--Subsequent Disclosures
3. Terms that change upon the occurrence of an event. An institution offering terms that will automatically change upon the occurrence of a stated event need not send an advance notice of the change provided the institution fully describes the conditions of the change in the account opening disclosures (and sends any change- in-term notices regardless of whether the changed term affects that consumer's account at that time).

Technically, the minor did get them. But they were two years old at the time. I am mostly worried about sharing PII for affiliate marketing. If they got the privacy notice when they were very young (we do not send annual notices) have they really been given the opportunity to opt out? The parent for sure has

So, was this account opened as a UTMA? If so, the minor was not a customer at that time, the custodian was.

Yes, you will need to provide disclosures to the 18-year old customer as they have not previously been a customer as defined in the regulation, nor would the disclosures provided 16 years ago be considered delivered to them.

If that was a UTMA account, the bank cannot do anything though. The current custodian or a new appointed custodian under State law would have to write a check to the minor who is now an adult and close the account and the minor can do whatever they want with the money, including opening a new account. UTMA accounts are not converted.

If this is not a UTMA account, I surely hope you have changed your processes regarding minor accounts. How can a two-year-old possibly be an account owner and signer?

Thanks for the response. This answers my question. I thought the minor did not meet the customer definition in Reg P until they reach adulthood, but needed confirmation.

I am still confused. So, the parent was on the account also as a joint account holder? Are you not just changing the terms of the account? I guess I am just confused as to why notice to one is not notice to all on joint accounts for any dislcosures and what that specifically has to do with the minor.

You have both Randy Carey and me confused with your question and explanation.

It is always helpful to describe the scenario completely to avoid leaving possible responders in the dark. We know the kid was about two years old when the account was opened. And you want to change the account type because the kid is approaching his 18th birthday, right? And you want to know whether you need to provide new account disclosures.

Is the account a joint account with a parent, or is the minor the only owner?

Is it a UTMA account with a custodian, or not?