02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
02/17/2019
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?
05/20/2018
Are Reg DD disclosures, especially the APY required when, for example, a customer negotiates a bumped up rate for 3 months?
03/11/2018
If we discontinue a debit cash back rewards program are we required to provide notice to the customer within a specified time frame, and are we required to notify them at all?
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?
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.
04/17/2016
We use a third-party service provider to manage some of the benefits of our “Platinum Account”. Are there possible UDAAP issues lurking here?
05/27/2013
If you stop offering the ability to write checks from your money market account, what disclosures or notice must you give to your customers?
04/09/2012
In order to have a NOW account, does the account contract have to disclose the reservation of the right at any time to require not less than 7 days notice in writing before any withdrawal from an interest bearing account?
09/05/2011
Does an excessive withdrawal fee need to be disclosed on the TISA if it is not an automatic fee? The bank has the option to charge it or not. Would it be considered an incidental fee in this case?
