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Are we required to notify each account owner on a joint account when there is a change in the method or location of the statement delivery? For example, what if a joint account owner signs up for e-statements without the other account owner’s knowledge? – IBA Compliance Connection

IBA Compliance Connection

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Are we required to notify each account owner on a joint account when there is a change in the method or location of the statement delivery? For example, what if a joint account owner signs up for e-statements without the other account owner’s knowledge?

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No, we do not believe it is necessary to notify account holders who are not receiving periodic statements about changes in the delivery method or location. Regulation E (for electronic fund transfer accounts), Regulation DD (for savings accounts) and Regulation Z (for open-end credit) permit you to provide periodic statements to only one of the accountholders for a jointly held account. Unless your account agreements or policies require you to send periodic statements to all accountholders on a joint account, notifications of changes in delivery method or location should be sent only to the accountholder who is receiving the periodic statements. If multiple joint accountholders are receiving statements (e.g., by request, or under your current practice), we recommend sending account notices to all accountholders who currently are receiving periodic statements.

For resources related to our guidance, please see below:

  • Regulation E, 12 CFR 1005.4(c)(2) (a financial institution need provide only one set of required disclosures and may provide them to any of the account holders on a joint account)
  • Regulation Z, 12 CFR 1026.5(d) (when there is more than one consumer on an account, disclosures may be made to either account owner)
  • Regulation DD, 12 CFR 1030.3(d) (permits disclosures to be made to any account owner on a joint account)