09/15/2024
I have a question about a CD special. The bank's rate sheet lists a 12-month CD as well as a 12-month CD Special that has a considerably higher interest rate/APY than the regular base CD. The bank also allows negotiation and will pay a higher rate to keep business. For the "special" and any other negotiated rate, the rate is only in effect for the initial term and at maturity will renew at the 12-month non-special rate.
I'm looking at 1030.5; Comment 5(a)(1)-1 and I am thinking that advance notice would be required since the terms are changing upon the occurrence of an event (renewal). There is nothing on the TIS disclosing that the initial term is a promotional period and that the CD will renew at the lower non-special rate in effect.
Am I thinking about this correctly?
02/11/2024
When orally quoting a deposit rates over the phone, if the APY is 3.00%, does the the employee need to state the APY as 3.00% or can they say the APY as 3%? Likewise if the APY was 3.50% do they need to say the APY is 3.50% or can they say the APY is 3.5%?
04/30/2023
With our Money Market account, we would like to pay higher rates on some accounts to allow us to retain top clients. The rate may vary depending on the customer relationship. We would not be advertising these rates. Would there be any compliance concern with this practice?
06/13/2021
During a conversion the bank made an error regarding our loans account in the customers favor. These were paying demand deposit accounts which had been overdrawn. We would like to raise the APR to charge the existing customers the correct rate. Since this would have an adverse impact on the customer, we would have to send the notice to all existing customers, at least 60 days in advance. The question would be is there a sample form that we could utilize to send to our existing customers?
08/23/2020
How do we resolve a conventional 30 year residential loan, originally floating at application, that was closed without being officially "locked," at the rate originally stated on the LE, which did state that the rate was floating? Will the resolution differ if the now current market rate has dropped lower than the original stated rate versus an increase in the rate?
10/28/2018
We have looked at Reg DD but cannot find where it even mentions this.
Are we required to tie IRA rates (variable or fixed) to an outside index? I think that back in the 1980’s when they first became available, it was a
best practice.
But I cannot find it mentioned anywhere now?
08/05/2018
I am trying to find more information regarding the rate information on savings disclosures. The rates are listed as tiered rates, but if a customer receives a special rate other than what is listed, does the disclosure need changed every time to list the special rate? Or when the rates do change, does the disclosure need changed every time, even if the rates will change soon after again? Right now, the disclosure states, "The interest rate and annual percentage yield may change. At our discretion, we may change the interest rate on the account daily."
01/07/2018
Offering Reg O Insider A Higher Rate on Deposit?
01/22/2017
I have been instructed to lead a project around compliance ramifications if negative interest rates were to occur in the US. With regard to deposit accounts, would all TISA and other initial disclosures need to be updated to reflect this change. Since the change in terms would negatively affect our customers. This would be quite an undertaking as we have 10 member banks. Would all of our advertisements have to be re-disclosed? Any feedback is greatly appreciated.
10/25/2015
We are trying to create an ARM loan and it will be on a 15-year note with rate changes every 5 years, basically changing twice. Is there a maximum ceiling rate/floor rate we can charge?