Skip to content

Definition of "Required Deposit"

Answered by: 

Question: 
We have experienced a change in examiner's interpretation of the "required deposit" box. This has been a Fed Box disclosure for over 20 years. Can you please give me the definition of exactly what a "required deposit" is and when the required deposit box is to be checked.
Answer: 

If you require that your borrower maintain a deposit account with your bank as a condition of the loan, this disclosure would be applicable. There are a couple of exceptions noted in footnote 45 in 226.18(r). The Official Staff Commentary gives more detail about these exceptions.

Where this definitely comes into play is with a CD-secured loan. But there can be other areas as well. If you require that your auto loan customers maintain a checking account with the bank to qualify, then this box would need to be checked (unless you are paying more than 5% on your checking, in which case I want to bank with you).

First published on BankersOnline.com 5/16/11

First published on 05/16/2011

Filed under: 
Filed under compliance as: 

Search Topics