Combined Deposit Statement Contents

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Question:

Pertaining to Reg DD and combined statements; Under 1030.6, a bank is not required to provide a periodic statement for CDs and IRAs. However, we are providing combined statements for a subset of our clients that that includes information on CDs and IRAs and other account types. The combined statements do not include APYs (as required by 1030.6) for these account types but includes a "current rate" and includes all the other elements that Reg DD specifies should be on the period statement if one is provided. The official interpretation of 1030.6 states that, "institutions may provide information about an account on the periodic statement for another account without triggering the disclosures required by this section, as long as ..." Our Vendor says that it cannot change "Current Rate" to APY on these combined statements, nor can it remove "Current Rate." Is this a technical violation of Reg DD? If so, what is the potential risk associated with this violation? I have not been able to find any enforcement actions on this issue to help us understand the risk.

Answer:

No, it's not a violation. You can include "interest rates and corresponding periodic rates applied to balances during the statement period." That doesn't require that you show the APY or an APY earned.