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#68103 - 03/18/03 04:31 PM Reg DD-Change in Fees
Anonymous
Unregistered

If some Reg DD fees will change (increase) and some will not, can the notice of change in terms list all the fees on the service charge brochure and indicate at the top of the notice that these fees are effective on the change date?

By doing so and indicating these are all the fees effective on the change date, does this eliminate the statement addressed in the commentary to 230.5(a)(1)that the change be highlighted in some manner? Or will those fees that will changed still have to have the amounts highlighted?

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#68104 - 03/18/03 04:37 PM Re: Reg DD-Change in Fees
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You need to bring the customer's attention to the specific fees that are changing (i.e., highlight, underline, bold).

From Reg DD Commentary: If an institution provides notice through revised account disclosures, the changed term must be highlighted in some manner. For example, institutions may note that a particular fee has been changed (also specifying the new amount)or use an accompanying letter that refers to the changed term.
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#68105 - 03/18/03 04:37 PM Re: Reg DD-Change in Fees
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
Posts: 2,301
Far from Calif
My reading of the commentary is that the changed term is actually supposed to be highlighted so just putting a new effective date at the top would not suffice.
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#68106 - 03/18/03 05:25 PM Re: Reg DD-Change in Fees
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
I agree with the replies above. You must tell me WHAT is changing.

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