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#1375528 - 04/16/10 06:04 PM Initial interest rate on TIS disclosure
Cher Offline
Member
Joined: Oct 2003
Posts: 98
Florida, USA
We have a tiered product that pays 0% interest on balances below a certain amount. The tiers and the related interest rates/APYs are disclosed in the "additional terms and conditions" section of our disclosure. Is this sufficient or do we need to disclose the initial interest rate that pertains to the particular amount being deposited at account opening time? We use a disclosure from a third party document system and there is a box that is checked that states "the interest rate and annual percentage yield for your account depend upon the applicable rate tier". I am thinking that since the complete tier rate structure is disclosed that will be ok. Any thoughts?

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#1376371 - 04/19/10 04:54 PM Re: Initial interest rate on TIS disclosure Cher
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,352
Galveston, TX
You are correct - complete discription of all tiers. The initial deposit is not a consideration for interest rate and APY disclosure.
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