Latest Compliance - Disclosures Topics

Promontory for Broker Deposits to Consumer- Reg DD

01/10/2021

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?

Disclosing Escrow Estimates

05/10/2020

Would escrow estimates be reflected on the LE/CD on a junior mortgage if those are being covered by the first?

ARM Programs-Rate and Payment Change Date

03/01/2020

Our bank would like to offer a 20/15, 25/15 and 30/15 loan where the interest rate is fixed for 15 years then changes one time for the remaining term. Everyone we've talked to says these are ARM loans. However, in our loan platform all ARM programs must have a subsequent rate and payment change date. Is anyone else offering these products? If so, how are they disclosing?

Reg E Type of Transfer/Type of Account

03/24/2019

Under Regulation E, section 1005.9(b), Banks are required to include the type of transfer and the type of account to or from which the transfer was made. The commentary doesn't specify how you disclose the type of account under this section (however, it does specify how to disclose this for terminal receipts under 9(a)). So, my question is, is it OK that our periodic statements just state "transfer from account XXXX" instead of specifying the account type or should it be stating transfer from checking/savings?

Prepaid Interest-TRID Loan Estimate and Closing

10/14/2018

Is prepaid interest included in the calculation for Total of Payments amount in the TRID Loan Estimate and Closing Disclosure?

Disclosures Required on Annual IRA Statement

07/01/2018

What disclosures are required on an annual IRA statement?

Reg DD Disclosures for Negotiated Rate? (APY)

05/20/2018

Are Reg DD disclosures, especially the APY required when, for example, a customer negotiates a bumped up rate for 3 months?

Considerations When Building TIS​ disclosures

03/11/2018

We are moving our accounts to a relationship style checking with service charge refunds with certain transactional behavior.(ACH, POS, eStatements,etc) What are some considerations we need to remember when building the TIS​ disclosures​?

Disclosure compliance automation

02/11/2018

How can we automate the tracking of our disclosures?

Rate Sheet Required for Interest Bearing Accounts?

01/14/2018

On interest bearing accounts, must a bank whether in person or via online e-disclosures provide a rate sheet to their clients or is this discretionary?