When advertising a CD special on a rate sheet that will be provided to customers, and the ad only indicates the CD special product name with a
statement that says, "ask us how to open your CD special," and nothing else, but the CD special has conditions and limitations that the regular CD
accounts do not, should a bank disclose on the rate sheet what those conditions and limits are that differ from the regular CD products that are
also listed on the rate sheet?
There is a fully disclosed addendum for the special that covers the Reg DD
disclosure requirements. However, this will only be provided if the special
is opened by the customer. My concern is that if the customer only requests
the rate sheet and doesn't open the account the customer will not receive
the addendum or the full scope of the special on the rate sheet and this may
be a little misleading if the customer comes back at a later date to open
the special and they find out there are conditions to be met on the product.
This is about an advertisement that offers a bonus to a customer and one of the conditions to be met in order to qualify for the bonus is having a set
number of debit transactions posted to the customer's account within a specific period of time. When disclosing this qualification in the ad for
the customer, should it be specified as "posted and cleared to your account" to be more clear and conspicuous or is the language "posted to your account"
Does Reg DD indicate the need to specify the term "cleared or completed"
when referring to posted?
Our bank is exploring the idea of a new CD product in which all the interest is paid up front on the date of initial deposit. In the case of early
withdrawal, are we able to deduct the penalty from the principal since there would be no interest accruing during the CD term?
I have been trying to find what the requirements are for giving bonuses to open a new account. There are advertisements everywhere of cash offerings, freebies, or giveaways. We’re still stuck on the value of offer cannot exceed $10, however we see TV ads offering $300 to open an account.
What compliance issues do we need to address if our offerings go beyond $10? As an example, April is Teach your Children to save month. Marketing has come up with a campaign that if you come by and get a piggy bank and bring it back full of coin with your child and use it to open an account, the bank will also deposit $10 into that new account, or it could be an existing account.
Our attorney posed a question to me that he received from a customer. He wants to know under what circumstance do we change our deposit disclosures? I told him when we have a regulatory change or a policy/product/service charge or other change. Also, I said if the change is adverse to the deposit customer we have to notify them in a certain number of days according the change requirement or regulatory requirement. If the change is to the customer's benefit, we may or may not do a mailing and just post it on the website, social media or on the their statement. Our attorney wants to know the general rules for account agreement changes, when to change them and where it appears regarding the adverse change or customer benefit change. Any thoughts?
Our company is wanting to offer Time Deposit accounts. I have read Reg. DD and I see that Time Deposits have certain restrictions on withdrawal periods and penalties but I don't think they are much different than Certificate of Deposits and Auto Save IRA CD's. Basically if we adhere to TISA requirements are we okay to offer these or should I be looking into any other regs or requirements?
Does the bank have to include dates in a deposit account periodic statement?
In accordance with Reg DD the subsequent disclosures are to be sent in advance of 20 days. How is this "in advance" counted. If sent before 20 days (18 days before mature date) it is noncompliant but if sent 23 days before maturity it is compliant?
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."
I was wanting to know if it is required to mail a monthly bank statement if there is no activity on the account? We have several customers who basically just use their account to cash checks and generally don't have any activity. Currently we mail the statement with no activity but I wasn't sure if it is required.