09/15/2024
I have a question about a CD special. The bank's rate sheet lists a 12-month CD as well as a 12-month CD Special that has a considerably higher interest rate/APY than the regular base CD. The bank also allows negotiation and will pay a higher rate to keep business. For the "special" and any other negotiated rate, the rate is only in effect for the initial term and at maturity will renew at the 12-month non-special rate.
I'm looking at 1030.5; Comment 5(a)(1)-1 and I am thinking that advance notice would be required since the terms are changing upon the occurrence of an event (renewal). There is nothing on the TIS disclosing that the initial term is a promotional period and that the CD will renew at the lower non-special rate in effect.
Am I thinking about this correctly?
02/11/2024
When orally quoting a deposit rates over the phone, if the APY is 3.00%, does the the employee need to state the APY as 3.00% or can they say the APY as 3%? Likewise if the APY was 3.50% do they need to say the APY is 3.50% or can they say the APY is 3.5%?
01/15/2023
Pertaining to Reg DD and combined statements; Under 1030.6, a bank is not required to provide a periodic statement for CDs and IRAs. However, we are providing combined statements for a subset of our clients that that includes information on CDs and IRAs and other account types.
The combined statements do not include APYs (as required by 1030.6) for these account types but includes a "current rate" and includes all the other elements that Reg DD specifies should be on the period statement if one is provided. The official interpretation of 1030.6 states that, "institutions may provide information about an account on the periodic statement for another account without triggering the disclosures required by this section, as long as ..." Our Vendor says that it cannot change "Current Rate" to APY on these combined statements, nor can it remove "Current Rate." Is this a technical violation of Reg DD? If so, what is the potential risk associated with this violation? I have not been able to find any enforcement actions on this issue to help us understand the risk.
02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
06/13/2021
During a conversion the bank made an error regarding our loans account in the customers favor. These were paying demand deposit accounts which had been overdrawn. We would like to raise the APR to charge the existing customers the correct rate. Since this would have an adverse impact on the customer, we would have to send the notice to all existing customers, at least 60 days in advance. The question would be is there a sample form that we could utilize to send to our existing customers?
05/13/2018
Is there a requirement on how many places after the decimal point to use when quoting rates on a rate sheet or advertisement? Two or three places?
05/13/2018
Is there a requirement on how many places after the decimal point to use when quoting rates on a rate sheet or advertisement? Two or three places?
02/11/2018
What all is required to advertise a special CD rate on an outside digital board? Does APY have to be spelled out? Is this sufficient?
12 Month CD 1.26%APY ASK US
10/01/2017
If we use postcards to advertise consumer loans can the APR disclosure be on the flip side or does it have to below the APR on the same side?
10/30/2016
If the interest rate disclosed in a promissory note is incorrect (it is lower than what is actually being charged), is that a Reg Z problem? What if the TILA disclosure is within tolerance and is considered correct, could this then be an issue with UDAAP?