We are not aware of any laws or regulations that would require a notice to customers when converting to combined account statements. Needless to say, you should be sensitive to a number of related issues, such as the accounts being owned by exactly the same customer or customers, and that statements for each of the accounts are sent with the same frequency as when sent by separate statements.

More specifically, Regulation E authorizes banks to combine any disclosures required under that regulation into a single statement for customers with multiple accounts at the same financial institution. 12 CFR 1005.4(c)(1). And, Regulation Z allows banks to combine deposit account and credit account statements, provided that credit transactions appear on the first page of such combined statements. Comment 1, Official Staff Commentary, 12 CFR 1026.7(b)(13).

Having said that, if the combined statements are for two or more consumer loan accounts that provide for different payment cycles, there is some possibility that UDAAP questions could be raised in some situations (such as with elderly customers).  Also, keep in mind that there are some laws — not relating to account statements — that require separate notices, and bank personnel should be cognizant that while combining periodic statements may be permissible, that should not be conflated with any specific requirements for separate statements.