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#687578 - 02/15/07 05:16 PM Updating Fees
complygirl Offline
Platinum Poster
Joined: Oct 2004
Posts: 822
midwest
We are currently in the process of updating some of our fees such as OD, stop payment, etc. in addition to updating some of our minimum balances to open specific types of accounts. We would like to simply provide an updated fee schedule with all of the updated fees. We would state on the schedule that the fee schedule is effective on May 1, 2007 for example.

What I am wondering about is whether or not there is a requirement to distinguish in some way (such as bold type) which fees are changing? We do not intent to state the old fee amount on the schedule. If we are required to distinguish which fees are changes could someone direct me to where this requirement is stated in the regulation? Any help would be greatly appreciated. Thanks.

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Operations Compliance
#687651 - 02/15/07 05:53 PM Re: Updating Fees complygirl
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
From the Reg DD commentary 230.5(a)(1)-1:

Form of notice. Institutions may provide a change-in-term notice on or with a periodic statement or in another mailing. 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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