Is it legal to pay to only a few customers a higher interest rate than disclosed and paid to other customers? I would think TISA would not allow this, but I can't find anything specific in the statute. We want to do this so as to not lose a large account.
We are thinking about offering a "bump-up" rate CD product. If we do, I know we need to include in the original TISA disclosure the terms of and conditions of the product to the customer, but at the time the customer exercises his right to "bump" the interest rate on the CD, do we need to provide him/her with a new TISA disclosure reflecting the new rate/APY or does the original TISA disclosure suffice, even though the rate/APY will not be the same?
Do we have to send updated TISA disclosures for the updated money market savings withdrawal limitations?
Are we required to provide TISA disclosures to business customers for business deposit accounts?
The Truth in Savings Act, at 12 C.F.R. section 230.4(a), states disclosures must be provided when an account is opened or a service is provided, whichever is earlier. As I understand it, the types of services include the use of ATMs, stopping payments on checks, etc. Does that mean that new account disclosures have to be provided each time an ATM is used or that full disclosures need to be provided before the first of either service and the new disclosures only need to be provided if the terms change?
When closing a consumer account due to stolen checks or a similar reason and opening another account of the same type (same fees, same name, etc.), is it necessary to provide all the disclosures that are normally provided at account opening? This question has come up because we are in the process of changing our account offerings; the new accounts will have different names, fees, etc. The new account TISA disclosures will reflect the new account offerings. When we do a "close and reopen" we can open the same account type as the customer's original account, however, the new account TISA disclosures will not include information on that account type. What is required in this situation?
We are a small community bank of less that $75M regulated by FDIC. We offer no Overdraft Protection other than the "sweep account" from another deposit account. What new Reg DD changes would affect our bank?
Are there any specific size/readability requirements relative to disclosures for Member FDIC,Equal Housing Lender Logos, and, if applicable, disclosures relative to TISA or TILA on billboards? I'm having difficulty understanding what is meant by "clear and conspicuous standards" and am interested in knowing if there are standards for the readability of these disclosures? Is there an industry practice relative to inches of fonts (regardless of the size of the billboard)?
This question is concerning the truth in savings disclosures at account openings. One of the affiliate banks I work with omitted, in error, the interest rate schedule section of the TISA new account disclosure from the time of conversion as a new affiliate of a bank holding company, until recently when it was discovered as an omission. The TISA has since been revised to include the interest rate schedule for the new accounts, however, new account holders for the past 7 months did not receive rate information at the time of new account opening for NOW, Savings and MMAs. Should the bank send out the revised account disclosures to all of the account holders who did not receive interest information at account opening for the last 7 months, or is the fact that these customers have since received periodic statements sufficient?
Anticipating that interest rates may eventually re-peak and start downward again (long view), we're considering adding a "call" feature to our certificates of deposit. The contract would allow the bank to unilaterally redeem any such time account with notice to the customer in the bank's sole discretion.Is there special wording that we need to add to our Regulation DD disclosures?