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How to Combine 3 Checking Accounts Into 1 Type

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Question: 
We are looking to combine 3 of our current checking accounts into a new type of excellent checking account that offers the customer lots of perks. What kind of disclosures and notices are we required to present to our current account holders of these 3 accounts before, during and/or after this process?
Answer: 

First, decide whether you will (1) continue to accept new accounts in the three current account offerings; (2) stop offering the current three accounts, but allow current holders of those account to continue with them; or (3) stop offering the current three accounts and migrate current account holders to the new offering.

With the first two alternatives, you can notify current account holders of the new offering, but you don't need to provide detailed disclosures or arrange any transition (new checks/new statement look and feel/changeover day, etc.).

But if you're going to eliminate the current three accounts, you will have to give your current customers at least 30 days advance notice; provide full account disclosures for the new account; arrange for new checks (if needed), etc.

First published on 03/30/2015

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