09/29/2024
I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date.
Here is an example: a CD term is 6 months and interest is paid every 30 days.
Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?
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%?
11/12/2023
May we run an ad offering a $3.00 gift to people who open a new account and current account holders, without offering the gift to the general public?
05/14/2023
My bank made changes to language in the fee schedule and depository disclosures, pertaining to return items and non sufficient funds representments and statement language. Is there any reason the bank needs to notify the customer of these changes?
04/30/2023
With our Money Market account, we would like to pay higher rates on some accounts to allow us to retain top clients. The rate may vary depending on the customer relationship. We would not be advertising these rates. Would there be any compliance concern with this practice?
04/02/2023
Our bank charges a telephone transfer fee. This was a new fee added recently. According to Reg E Section 1005.7(b)(5), we must disclose any fees for EFTs or the right to make transfers. I wasn't sure if the fees described in Reg DD applied to this type of transfer fee. Would we need to disclose this fee 21 days prior to the change?
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.
05/29/2022
Are there limits or reporting requirements on the dollar amount for gifts being provided to customers and non-customers attending a bank grand opening?
There will be no requirements to open an account. Anyone who attends the grand opening will receive a gift. What regulation would apply to this?
05/01/2022
How can I add someone to a deposit account? Is there a specific procedure for the signature cards or disclosures if they're even needed?