Question:
Our FI is planning on using Promontory to offer broker deposits to consumers.
I have thought that Reg DD, section 1030.4 thru 1030.6 (Account
Disclosures) apply, however the Agreement and periodic statement don't specifically
address by Reg DD the required elements. For example, their Agreement states
accrued interest will be credited "at least once each month" vs. a specific
frequency, and it does not reference if accrued interest will be paid or not
paid if the account is closed, and refers to the APYE as "Statement Period
Yield".
We have just received communication from the vendor and they are telling us
that "A Relationship Institution is a “deposit broker” for purposes of
TISA and, as such, is subject only to the advertisement provisions of Reg
DD." But they don't even spell out at least once Annual Percentage Yield.
Is our FI required to meet all the requirements of Reg DD as if the consumer
were opening one or our MMAs?
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