In the truth in savings, do you need to state any age restriction or requirements to have the account if they do not affect the assessment of a fee? We have an account for seniors. The account does not have any fees associated with it, there are no transaction limitation or restrictions, interest is paid based on minimum balances disclosed, but you have to be 55 or older to get the account. Do I need to put that in the TISA? If so, where should it go? I do not see anything mentioned in the reg other than transaction limitations.

Just playing the devil's advocate, as you mentioned it is not directly addressed. Is this a not transaction limitation? You cannot transact at all if you are not at least 55?

I thought you could not have a "senior" account for under age 62. Maybe I'm thinking of Reg B and credit purposes for discrimination?

Sorry, I did find it relates to a credit product. The last bank I worked for raised the age of their senior account to 62, but maybe it was in case it became overdrawn because then it becomes a loan??

More likely related to reductions in lending related services such as discount on home loan closing, discount on auto loan or something like that.

Our thoughts were that it is a product limitation not a transaction limitation. if you were not 55 you would not be offered or have this product; therefore you must be at least 55 to have it, therefore there is no transaction limitation.

Regulation DD does not require you to disclose age limitations.