does not want to incur the fee, then we would hold their statement for pickup for 30 days. After 30 days, we would destroy their statement. Does this violate Regulation E requirements? A: The general rule in Regulation E is that the bank must “send a periodic statement for each monthly cycle in which an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred.” Holding statements for pick up is something that the bank may permit — but only at the customer’s request. It may not require that customers come in to pick up their statements. The requirement is to send the statements to customers. One other exception provides that a financial institution need not send statements to consumers whose accounts are inactive as defined by the institution. I have only seen fees for printed and mailed statements as an alternative to electronic statements. If the customer does not want e-statements, then they are charged a fee to cover printing and mailing costs for a physical statement. So, in either case, a statement is sent — a free e-statement or a fee-charged hard copy statement. TISA. Q: Our bank wants to send the following change in the terms message on statements: Important Notice: Previously, the tiers associated with your checking and savings accounts remained unchanged; however, they are now subject to change. Additionally, for accounts that do not currently have tiers, we reserve the right to introduce tiered structures in the future as part of our ongoing efforts to enhance our banking services. As a result, your Truth in Savings disclosure has been revised to reflect these changes. You can obtain a copy of the updated disclosure by visiting any of our financial centers, emailing us at ___@___.com or calling us at ___. If you have any questions or need further information, we’re happy to assist. We want to have the option to add tiers to products that are not tiered or adjust tiers to products in the future without any additional disclosure beyond the statement message below. The Truth-in-Savings disclosures would be updated to include language with the bank’s option to add or modify tiers. A: Whether the changes benefit the customers is not clear from the limited information we have been given here. If a tier(s) being added to an existing tiered product has higher interest rates than the existing tier structure, then that benefits the customer. If the bottom tier of a newly-added tiered structure equals the existing rate on the customer’s deposit product, with the remaining Community Banker 15
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