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#136717 - 12/04/03 07:33 PM Tiered Rate MMDA - New Twist
SJB Offline
Diamond Poster
Joined: Jun 2002
Posts: 1,210
This is a followup to this old thread: Tiered Rate Account
In proposed advertising, marketing wants to avoid listing all the tiers with their corresponding thresholds and APYs and just show the LOWEST tier and mention that larger balances earn higher yields. (I know, normally they want to just list the highest APY.)
I have looked through Reg DD and it does not seem to provide any safe harbor for advertising just the lowest tier and lowest APY.
My opinions are not legal advice and are worth what you paid for them.

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#136718 - 12/04/03 07:39 PM Re: Tiered Rate MMDA - New Twist
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
My thought, for what it's worth --

While this approach avoids the "bait and switch" allegation of deceptively using only the higher tiers, the Fed didn't allow for it when writing the regulation.

Unless you can obtain a written approval from the Fed's staff for your Marketing Department's suggestion, I'd recommend against using it.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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