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.
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?
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