It has been brought to my attention that the fee described on our Reg DD disclosure is different than how the fee is described on the monthly statement. For example, on the Reg DD disclosure we have "Debit/ATM Card Fee" while on the customer's statement, the description is "ATM Annual Fee". Is this okay or do they need to be described exactly the same? If they need to be exact, can I change the term on the TISA disclosure without having to notify our customers of this change?

This is when I wonder why I am in Compliance.

Look to Comment #2 to section 230.3(a) in the Official Staff Interpretations (Supplement I to the regulation):

2. Consistent terminology. Institutions must use consistent terminology to describe terms or features required to be disclosed. For example, if an institution describes a monthly fee (regardless of account activity) as a ``monthly service fee'' in account-opening disclosures, the periodic statement and change-in-term notices must use the same terminology so that consumers can readily identify the fee.

It's OK to abbreviate slightly on the statement if necessary, but the "name" you assign to a fee in your disclosure document should be the "name" you use on your statement.

Thank you for your reply.

It sounds as though I need to make some changes. In your opinion, can I change the verbiage on the disclosures (to match the statements) without notifying customers about this minor change?

I think it's a low risk item.