Answer:
From the regulation:
Sec. 1030.5 Subsequent disclosures.
(a) Change in terms. (1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under Sec. 1030.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer. The notice shall include the effective date of the change. The notice shall be mailed or delivered at least 30 calendar days before the effective date of the change.
The advance notice requirement only applies to "a term requried to be disclosed." Fees that are required to be disclosed are described elsewhere as those that are "in connection with the account." Using your examples, changes requiring notice would include increases in overdraft fees, service charges, and stop payment fees.
Wire transfer fees are not in connection with the account. You were not required to mention them in the initial disclosure. If you do change them, you are not required to give advance notice of the change even if you gratuitiously included them in the initial disclosure.
First published on BankersOnline.com 12/17/12
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