In the October issue of Banking on BCC, we walked through the compliance requirements related to a change in terms under Regulation DD (Truth in Savings), Regulation E (Electronic Fund Transfers and Regulation CC (Expedited Funds Availability). Here is an excerpt from the discussion on Regulation DD:
The Truth in Savings Act (§1030.5 - Regulation DD) specifies when subsequent disclosures are required to be made for an account. Subsection (a) addresses “change in terms” and states that:
A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under §1030.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer…
In other words, if there is a change to any of the required information and that change could either reduce the annual percentage yield or affect the consumer adversely, institutions must notify the consumer before the change takes effect. This notification must clearly state what’s changing and …include the effective date of the change…. It must also …be mailed or delivered at least 30 calendar days before the effective date of the change.
While notice of a change in terms must be in writing, there are some different options. One would be to include the notice on or with a periodic statement. This could be a message on the statement itself or as an insert on a separate document. An institution could also choose to provide notice in an entirely separate mailing or even provide revised account disclosures.
There are some additional considerations; however, with some of these methods which we address in the article.
Be sure to check it out!
Published 2026/10/14