If I compare the APY that we are disclosing on the bank lobby rate sheet, the actual periodic statement and the Truth in Savings Disclosures, there may be 3 different rates. All of the rates are within tolerance for APY purposes. The differences are due to rounding and how many decimal points are calculated using our platform disclosure program, our APY modeling application and our core processing system. Do we need to get these all in sync?

No. The APYE on statements reflects a calculation based on the actual amount of interest earned and the average balance in the account during the period. It's affected by balance changes, use of collected vs. ledger balance for interest purposes, application of different rates in a tiered system, etc. In fact, it is unusual for the APYE to be the same as the APY in account disclosures or in ads. It's also affected by rounding, particularly when very small amounts are involved.

John i have a question regarding disclosure of rates. Currently we offer a 25 basis pt bump up for customers who qualify for a particular relationship with us. The system will automatically tell us if the customer is a ______. I have recently noticed that when the front line staff open CDs for these customers they are adding (done manually) the bump to the stated rate. The rate sheet that we give customers shows the 25 basis pts added to the APY. Is there too much of a discrepency here?

Thanks for your response

If you know that the customer qualifies for the increased rate at the time the CD is opened, the CD contract and disclosures should reflect the actual rate and APY that will apply.

Once ran accross rougue examiner that got bent out of shape by rounding the APR up to the nearest 1000th. (1.719 becomes 1.72). I can not find anything in DD Apend A 230 that helps substantiate this. Any ideas?

Reg DD requires you round and express to the 100th. 1.72 would be correct. Refer to §230.3(f).