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#689882 - 02/20/07 08:48 PM Notification of Daily Overdraft Charge
kburrows Offline
Junior Member
kburrows
Joined: Nov 2006
Posts: 35
Iowa
When implementing a daily overdraft charge on consumer accounts, must the Truth In Savings/Terms and Conditions of Your Account be altered to include the fee, or can we notify consumers by another route?

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Operations Compliance
#689906 - 02/20/07 09:07 PM Re: Notification of Daily Overdraft Charge kburrows
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Well, you need to provide prospective customers of the new fee, so whatever "bundle" of disclosures you provide at account opening will have to have it.

You can notify your existing consumer customers by any written means you wish to employ, except that if you want to do it electronically, the consumer must have already signed up for electronic disclosures, in an e-Sign compliant mode.
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John S. Burnett
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#689920 - 02/20/07 09:15 PM Re: Notification of Daily Overdraft Charge John Burnett
kburrows Offline
Junior Member
kburrows
Joined: Nov 2006
Posts: 35
Iowa
Thanks, John. That makes sense.

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