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Highnote provides you with templates for Cardholder Agreements.
Should there be changes to the agreement, it should be redlined, meaning changes tracked, and it will undergo a collateral review.
Given this is a legal document it may take longer than the 13 to 15 business day Service Level Agreement timeframe pending the amount of redlines.
Revisions required will undergo a separate review once changes are made.
Changes should be tracked and comments should be addressed within the document.
A clean version with the approved date must be sent back to Highnote.
Once the document is approved, Highnote responds back with this confirmation.
Ensure there is clear language around closing an account, defining when this can occur and how an account becomes inactive.
Highnote provides you with templates for Short Form Disclosures.
Regulation E identifies the requirements for the short form disclosures. A model template can be found Regulation E, 1005 A-10 along with more information on the Short Form Disclosures based upon different account types.
In addition to the formatting requirements listed for the short form disclosure for Prepaid Accounts, the short form disclosure for Payroll Accounts or Card Products must include a statement regarding wage or salary payment options. For example, “You do not have to accept this payroll card. Ask your employer about other ways to receive your wages” or “You have several options to receive your wages (list options) or this payroll card. Tell your employer which option you chose.” This statement must be located at the top of the short form disclosure.
Highnote provides you with templates for Long Form Disclosures.
Regulation E identifies the requirements for the short form disclosures. A model template can be found Regulation E, 1005 A-10f along with more information on the Long Form Disclosures based upon different account types.
The USA PATRIOT Act must be disclosed when a consumer’s personal information is collected. Personal information includes: (1) customer name, (2) date of birth, (3) address, and (4) identification number. The following are guidelines concerning when and where the PATRIOT Act needs to be disclosed.
There are three (3) options for the location of the PATRIOT Act Disclosure
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account
Highnote provides you with instructions using the Privacy Notice Online Form Builder offered by Federal Reserve. It should be provided when a customer relationship is established, meaning enter into a continuing relationship. See Regulation P, 1016.4 for when initial Privacy Notice is required for consumers.
Regulation P identifies the requirements for the Privacy Notice form. A model template can be found Regulation P, Appendix to Part 1016 along with more information on completing the Privacy Notice form.
The general rule is that you cannot share (directly or indirectly) nonpublic personal information about a consumer to a nonaffiliated third party unless the consumer opts out. Opt-out notice is not required when the product discloses nonpublic personal information as necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes, meaning sending information to a network or processor.
Common definitions to consider when completing the Privacy Notice form: