Compliance Question of the Week

We are going to institute a new fee for non-member check cashing. Do we have to send out a 30 day advance change in terms notice?

No.  While truth in savings does require you to send a change in terms notice for any change in a term that is required to be disclosed under 707.4, if the change may reduce the annual percentage yield or adversely affect the member, a fee for non-member check cashing would not fall into this category.

You would want to update your fee schedule and make the non-member aware of the fee prior to cashing the check.

Related Links:

12 CFR 707.4
12 CFR 707.5
Truth in Savings Commentary

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Advocacy News, Around the NW, Compliance.