I'll add two cents here: The regulation requires, when stating how interest shall be calculated for input to the APY formula, that, "In determining the total interest figure to be used in the formula, institutions shall assume that all principal and interest remain on deposit for the entire term and that no other transactions (deposits or withdrawals) occur during the term."
Footnote 3 to Appendix A says: "This assumption shall not be used if an institution requires, as a condition of the account, that consumers withdraw interest during the term. In such a case, the interest (and annual percentage yield calculation) shall reflect that requirement."
I read these requirements to mean that, if the bank has a product that compounds and pays under certain rules, the APY to be disclosed must reflect those rules, regardless of the fact that the consumer has obtained an exception by asking that interest be paid out periodically during the term of the deposit. Only if the bank requires the payout does the APY reflect the payout.
I agree that the compounding and crediting frequency must reflect the actual (as contrasted with the "as designed") way the specific account works.
The apparent conflict between the disclosure of the actual compounding and crediting frequency and the "as designed" APY is reconciled by the required disclosure that the APY assumes that interest stays with the account.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8