06/20/2011
We have a somewhat unique checking product - we pay 4% on balances up to $15,000 and 0% above that. Our disclosures indicate dividend rate of 3.928% and APY of 4%. If a member has $15,000 or more on deposit their return is the 3.928% because there is no compounding as we pay 0% on their monthly dividend. Is this accurate? Seems if we change dividend rate to 4% then APY will be more than 4% for those with balances under $15,000.
04/12/2010
We want to send letters to the parents of junior and senior high school students to try to get student accounts. We state in the letter we will deposit $25 into an account upon the account being opened. Can you see any pitfalls here? What if we address the letters specifically to the student, requiring parents to accompany the student to open the account?
03/01/2010
I'm doing a Reg DD/TISA audit. Our marketing department states that if the radio ad is under thirty seconds, we don't have to do TISA disclosures in the ad. Is this correct and/or can somone direct me to where it talks about this in the reg?
04/20/2009
When giving a gift card for opening a checking account, other than the requirements of what needs to be in the advertisement, do we have to disclose this on the TISA disclosures too?
10/20/2008
As a sponsor to a local high school football team, our bank was listed on the back outside page of the football program and handed out to the crowds at the stadium. Do the logo requirements still exist with a sponsorship in the same way they do with a normal advertisement?
12/17/2007
Can we establish a money market account that pays interest quarterly?
06/25/2007
We are designing a brochure for our gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
05/28/2007
We are designing a brochure for our Gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
03/19/2007
Our marketing department would like to issue lapel pins to our officers that say, "15.5, ask me how". This is in reference to an interest bearing checking account product that we have. Even though it does not say "15.5%", I still believe this would be viewed as a percentage rate by the regulators and therefore requires all of the information that goes along with a triggering term (including the term "Annual Percentage Rate"). Their contention is that the individual wearing the pin can make all of the required disclosure. I'm not so sure that this is acceptable. What do you think?
09/25/2006
What obligation does a bank have to follow up with matured but not redeemed CDs? After the final maturity notice, is it mandated anywhere that we contact these customers for redemption or convert their CDs to an interest bearing demand deposit account?