Answer:
by Ken Goliiher:
See 1030.8(c). If it is included in an advertisement, the APY is a "triggering term" which requires you to list several features of the account, including the interest rate.
Answer:
by Jim Bedsole:
Ken, I'm not seeing anything in 1030.8(c) that requires the interest rate be stated when the APY is provided. The APY is a triggering term, but the listed additional requirements are:
- For variable rate accounts, a statement that the rate may change after opening
- Time APY is offered, or a statement that the APY is current as of a specified date
- Min balance to obtain the APY (including info for each tier in tiered rate)
- Min opening deposit, if greater than min balance to get the APY
- Statement about effect of fees
- Time deposit features (if applicable)
I've always understood that the interest rate is optional in deposit advertising, but if it is included, should be in conjunction with, but not more conspicuous than the APY - 1030.8(b)
Answer:
by Brian Crow:
1030.4(b)(1)(i) requires that both the interest and APY be included on deposit disclosures. 1030.8(b) states that if an ad states a rate, it must state the APY and "may" state the interest rate. In other words, the interest rate does not have to be included in advertisements.
Answer:
by Ken Golliher:
Okey, dokey!
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