We have old checking accounts that the bank no longer offers. These older accounts included discounts on safe deposit boxes and checks and $10,000 Accidental Death Insurance coverage ($20,000 when airline passenger) as well the option to purchase family coverage for an additional $11 per month. Management would like to convert those accounts to a new checking accounts that will not include the discounts or the Accidental Death Insurance coverage. There is a plan to send a letter to explain the conversion and a debate about whether disclosures would be required.

1. Would all the new account disclosures be required for the new account they are moved into (TIS, Fee Schedule, Funds Availability, Overdraft, EFT, Reg E Opt-In, Terms and Conditions, Privacy Notice, Substitute Check Disclosure)? We in Compliance think these would be required, but have been challenged so need confirmation that all the usual new account disclosures would be a requirement.

2. Will the loss of the Accidental Death Insurance coverage trigger other disclosure requirements?

I think you need to read those insurance policies to see how and if you can cancel them.

Thanks. Good point. Do you agree the new account disclosures would be required.

Well, I assume there are going to be other changed terms. Whether you need to give them all new disclosures will depend on what those are, maybe the age of the accounts, how sure they have received all changed term documentation since the accounts were opened. All those are risk factors.