We have our deposit account rates located on our website. We have a seperate link that includes all required disclosures. While conducting a review of our website, i found that a consumer has the option to print a rate sheet in PDF format, however the disclosures required under Reg. DD do not print out.

If the consumer is able to print the rate sheet from our internet site, are the trigger disclosures required to print out with the rate sheet?

I'm gonna say Yes.

I strongly suspect that while this may not specifically be discussed in the rules of "advertising" the ability to print would take this from an on-line scenario to a "printed advertisement" scenario which would then require you to disclose the additional information at that time. (does your branding print too when they print the PDF?? That would definitely make it a print ad??)

My vote, take away the ability to print... or suffer the reporgamming it takes to get your disclosure to print with your rates and without being a part of the advertisement in the first place.