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#20052 - 06/07/02 07:20 PM Tierred rates on indoor signs
BKB Offline
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BKB
Joined: May 2002
Posts: 120
Midwest
I need clarification on whether all tiers need to be disclosed when advertising rates and APYs for tiered accounts on both indoor signs and telephone response machines. For example, if a bank has a four tiered money market account but chooses to only display the rate and APY for the highest tier, along with the required minimum balance for that rate tier - would that be okay?

I am reading the commentary to Reg. DD and section 230.8(a)2. states "An indoor sign advertising an annual percentage yield is not misleading or inaccurate when:
i. For a tiered-rate account, it also provides the lower dollar amount of the tier corresponding to the advertised annual percentage yield".
I can read this to say it is okay to only display any or all tiers.

Now, reading commentary 230.8(b)1. Tiered-rate accounts states "An advertisement for a tiered-rate account that states an annual percentage yield must also state the annual percentage yield for each tier, along with the minimum balance requirements." I beleive this is the general rule for all advertisements, before the exemptions of certain media.

Finally, in regards to telephone response machine rates, commentary 230.8(e)(1)(iii) states "Solicitations for a tiered-rate account made through telephone response machines must provide the annual percentage yields and the balance requirements applicable to each tier." I read this to indicate if a bank wants to disclose any tier rate, it must disclose all tiers.

Thanks for your help.

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#20053 - 06/07/02 11:17 PM Re: Tierred rates on indoor signs
RVFlyboy Offline
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RVFlyboy
Joined: Oct 2000
Posts: 5,992
Soaring over Georgia
Reg DD ยง230.8(e)(2)(i) says that indoor signs are exempt from all of sections 230.8(b), (c), (d), and (e)(1). And you already provided your citation for the telephone response. You don't need all tiers for the indoor sign, but you do need all tiers for the telephone response.
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