Answer:
Your legal counsel is asking these questions of you? I suggest you find a new legal counsel that is versed in contract law and has some knowledge of Regulation DD and E.
Otherwise, tell them to review 1005.8 and 1030.5.
General Rules for Account Agreement Changes
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Question:
Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
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