Compliance Q&A: TISA Disclosures and Regulation DD

Q: We are in the process of changing our TISA disclosures and are going to be sending out the updated disclosures soon.  We are going to make sure to send out the notices at least 30 days before the effective date of any changes, but are we required to send disclosures to all account holders?  If there are multiple account holders on one account, can we just send the updated disclosures to one account holder, or do we have to send it to all account holders on that account?

A: Regulation DD indicates that if you have more than one account holder on an account that you are only required to send the disclosures to any account holder.  There is no indication in the regulation as to which account holder you must send it to, so it would be up to the bank to pick which account holder is going to be the recipient of revised disclosures.

“(d) Multiple consumers. If an account is held by more than one consumer, disclosures may be made to any one of the consumers.” 12 CFR 1030.3(d),

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