We offer a free account with no minimum balance requirement. It doesn't pay interest. We disclose the minimum opening balance amount in the account opening disclosures. As far as advertising ads, account brochures, website, are we required to list what the minimum opening balance is for this account? We used to put an asterisk next to the name of this account and then list the minimum opening balance at the bottom of the advertisement. However, it looks like Reg DD only requires that a minimum opening balance be listed if the annual percentage yield is stated in an advertisement. Marketing would like move away from the asterisk and account specifics at the bottom when no APY is listed. Any reason we wouldn't want to do that?

Since there is no minimum balance necessary to obtain the advertised annual percentage yield, then the opening balance requirement is greater.

1030.8(c)(4) Minimum opening deposit. The minimum deposit required to open the account, if it is greater than the minimum balance necessary to obtain the advertised annual percentage yield.