Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
We acquired several commercial deposit accounts from another institution, which we have left on “waive” status (meaning that we waive any fees that normally would be charged). We intend to convert these accounts to a different account type with minimal fees. How should we disclose this change? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We acquired several commercial deposit accounts from another institution, which we have left on “waive” status (meaning that we waive any fees that normally would be charged). We intend to convert these accounts to a different account type with minimal fees. How should we disclose this change?

—

by

We are not aware of any disclosure or advance notice requirements that would apply to commercial accounts. However, we recommend executing new account agreements with the customers to reflect the new account terms, accompanied with the appropriate disclosures. In addition, you should check these customers' legacy account agreements to make sure there are no advance notification or disclosure requirements.