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Changing TISA Booklet for Deposit Accts. (Reg DD)

Question: 
When changing the Truth in Savings booklet for deposit accounts, is there a dual disclosure requirement (the new and the old TISA) for new accounts opened within the 30 days from when the change in terms notice is mailed and the date of the actual change in terms? What regulation or guidance dictates the dual disclosure requirement? I don't see any reference within Reg DD.
Answer: 

by Ken Golliher:

I'm opening an account on the 15th and the fees are changing on the 30th? The disclosure I receive on the 15th should be accurate at the time of receipt. It's impossible for me to get 30 days notice of the changes, so you tell me about them at the same time; i.e. you give me the current disclosure, then you give me a second piece of paper with the changes and their effective date.

I made that up... grin

Answer: 

by Randy Carey:

Made up or not, it is the way it happens. The Bank discloses the costs at opening with a disclosure and the new costs on xx/xx/xx date. The consumer has full knowledge of the costs and if they are not happy, since they receive the disclosures at account opening, they can always vote with their feet and not open the account.

First published on 03/12/2017

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