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Trust/Estate Require Same Disclosures As Retail?

Answered by: 
John Burnett

Question: 
During a recent webinar it was stated that Trust and Estate Accounts do not require the same regulatory disclosures as retail accounts. It was even recommended that they be carried as commercial and not retail accounts. This was news to the bankers listening to the webinar. Is it true they do not require the same disclosures as other retail accounts?
Answer: 

Because they don't meet the definitions of consumer in some of the regulations - - Regulations E and DD leap to mind - - they aren't covered and should not receive the consumer disclosures. On the other hand, they will be covered by Regulation CC and by the "zero liability" provisions of Visa/MasterCard rules. Some banks deliver the consumer disclosures nevertheless, with a disclaimer stating their restricted scope.

First published on BankersOnline.com 3/4/13

First published on 03/04/2013

Filed under: 
Compliance
Filed under compliance as: 
Disclosures
Estate
IT

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