Must we provide online deposit account opening disclosures on our website?

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Question:

We allow customers to open deposit accounts online. We’d prefer to keep disclosures (especially our rate and fee sheets) off our website, so that the competition can’t see them. Must we provide TISA disclosures up front, or can we mail them later? I seem to remember Reg DD allows us to send disclosures up to 10 days later when the customer isn’t at the bank.

Answer:

You must provide all TISA disclosures (including rate and fee information) to consumers opening an online account BEFORE the account is opened or a service is provided. The provision you refer to at 1030.4(a) does not apply to accounts opened on your website. You could put the disclosures in the online account opening flow, thereby making it less visible to the competition, but it does need to be provided before the customer transacts something, which would include submitting the opening deposit.

Want to learn more about how to comply with Reg DD requirements? Sign up to attend the upcoming webinar “To Tell the Truth: TISA, Reg DD and Reg D” on January 17, 2024!

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Learn more about Rebekah Leonard’s To Tell the Truth: TISA, Reg DD and Reg D webinar.