John Smith's checking account statement is currently produced on the 3rd Tuesday of each month.

If his account is changed so that the statement is now produced on the 3rd Thursday of each month, do we need to notify him?

If we change his account so the statement is now produced on the 2nd Thursday of each month, do we need to notify him?

I don't see this as a negative so I don't think that disclosure needs to be sent 30-days prior to the change, but it would have to happen within the 30-days following the change. Comments?

Reg DD requires advance notice of change for anything that is detrimental only when it was required to be included in the initial disclosure. You are not required to tell the customer what statement cycle they are in, so you are not required to tell them if you are changing that cycle.

There will undoubtedly be different opinions as whether courtesy would suggest a notice is necessary. My rule of thumb would be that any statement message that eliminates a few phone calls is worthwhile.

Since you are changing the terms of an aspect of the consumer's account, I think advance notice to the customer would be warranted. The customer may feel strongly about the timing of his statement and may not appreciate the change. Advance notice gives the customer a chance to make other arrangements if needed for some reason.

I would agree with Ken - since many statement cycles are based on the account type, and usually individual account types do not specifically disclose the cycle date, I don;t believe you need to redisclose. The way I look at it, if I have a customer who turns 55 and I switch them to a Senior Account because it eliminated their minimum balance requirement, I do not also advise them that their cycle date will change.

I couldn't imagine disclosing this to a consumer. It isn't a change in terms. No notice is sent if there is a holiday and that delays or accelerates statement production.

I wouldn't read extra work into this.

The consensus is that notice isn't required, but perhaps you should draw your client's attention to the change in a notice with/on his statement, especially if you cut his statement period short so that some items are deferred to the following month.

Regulation E, which is the only rule requiring monthly statements, even gives you an out here. In the Commentary, when discussing the monthly statement cycle requirement, it requires cycles that are more or less equal and end approximately at the same date each month, but then goes on to say that you can ignore than when changing statement cycle dates.