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#1299272 - 12/04/09 07:59 PM Requirement to obtain APY
CaseyBoo30 Offline
Gold Star
Joined: Feb 2007
Posts: 262
Winchester, KY
Is there an issue if a Bank requires the customer to make a certain number of debit card transactions monthly, have one or more direct deposits and/or auto debits and online bill payments to obtain the APY on an account as opposed to requiring a minimum balance?

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#1299513 - 12/04/09 10:44 PM Re: Requirement to obtain APY CaseyBoo30
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Not according to one vendor who has sold a product to over 600 community banks and credit unions across these United States, and their legal counsel......in one sense, to me anyway, it's no different than a tiered account (where to get a certain rate you must have xx dollars on deposit)
Our compliance consultants reviewed the marketing materials thoroughly before signing off....
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#1299582 - 12/05/09 12:06 AM Re: Requirement to obtain APY RBanker
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
I can't find the release, but the regulators opined on this type of program and established that some of the current practices by banks violated the Truth-in-Savings Act. Maybe someone else can remember when that was released and by whom. I believe one of them was that you could pay additional interest if they met specific criteria, but you could not - not pay interest on the account.
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