04/10/2006
This question is concerning the truth in savings disclosures at account openings. One of the affiliate banks I work with omitted, in error, the interest rate schedule section of the TISA new account disclosure from the time of conversion as a new affiliate of a bank holding company, until recently when it was discovered as an omission. The TISA has since been revised to include the interest rate schedule for the new accounts, however, new account holders for the past 7 months did not receive rate information at the time of new account opening for NOW, Savings and MMAs. Should the bank send out the revised account disclosures to all of the account holders who did not receive interest information at account opening for the last 7 months, or is the fact that these customers have since received periodic statements sufficient?
11/29/2004
Anticipating that interest rates may eventually re-peak and start downward again (long view), we're considering adding a "call" feature to our certificates of deposit. The contract would allow the bank to unilaterally redeem any such time account with notice to the customer in the bank's sole discretion.Is there special wording that we need to add to our Regulation DD disclosures?
06/07/2004
If a customer takes out a fixed-rate 12-month certificate of deposit and he wants a check monthly for the interest, are the rate and the annual percentage yield that you type on the certificate the same since nothing is compounding?
06/23/2003
For TISA compliance purposes, are CD's and time deposits treated the same or differently?
06/09/2003
We have accumulated many accounts that are "no address" accounts. These have accumulated due to the customer not keeping us notified of a new or forwarding address. At one time, most of the accounts were service charged over a period of time and closed on their own due to a zero balance. Since that time, we have merged our regular checking product into a product that doesn't have a monthly service fee, therefore, most of the accounts are no longer service charged and would stay at their current balance (63% of them have less than $50 on deposit) until the funds would be escheated. NOW... the question....we are exploring the opportunity of implementing a service fee for "no current address" accounts. Our initial discussion with compliance was that we could implement that fee to all future "no address accounts" but not to the existing ones since we couldn't truly "Notify" them of the adverse change. I want to wholeheartedly disagree with that since we did disclose at the time the customer opened the account that it was their responsibility to notify us of any address changes.
05/12/2003
Regarding Truth In Savings Disclosures for Certificates of Deposit with terms over one year. If a bank does not compound interest on CDs with terms over one year, pays simple interest, and allows the customer to add on the interest earned for the first year to the original amount, is it proper to mark the TISA disclosure as "CD not compounding and interest credited upon maturity of CD"?
09/02/2002
Are there any available APY calculation tools other than the one the OCC has? We have some savings statements that are mailed semiannually and the OCC calculator does not allow entering that number of daily balances.
07/15/2002
If a certificate of deposit is redeemed early (not during the allowed grace days), do we have the option of paying the accrued interest? I was told that we can waive the early withdrawal penalty if we choose, but that we still have to pay the accrued interest.
06/17/2002
If a certificate of deposit is redeemed early (not during the allowed grace days), do we have the option of paying the accrued interest? I was told that we can waive the early withdrawal penalty if we choose, but that we still have to pay the accrued interest.
03/04/2002
I'd like to offer a product to banks that they may like to use for new and existing account promotions. I was informed of a "Toaster Rule" that goes into affect if a gift exceeds $10 or $20, depending on account size. Then, the bank would be subject to additional taxes. Is this part of Regulation DD,12 CFR 230.2(f)? Where can I obtain the complete compliance and regulation info?