Answer:
Answer - David:There's no regulatory requirement, however, the agreement provides the legal agreement between the financial institution and the customer. It's only prudent to have such an agreement.
Answer:
Answer - Andy:In the lessons learned category, also look at your ATM/debit cards. For a long time we had only our Reg. E disclosure to depend on. No separate card agreement was required and we didn't have one. But I had an examiner point out that the cards we issued did refer to one. So we either needed to change the cards, or have a separate agreemnet. We authored some additional terms that were best disclosed in writing and created our agreement.
First published on BankersOnline.com 5/07/07
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