Our ops center made an error with a few of our CD's. The disclosures say that interest is compounded and credited annually, which it is.

The APY calculations, however, were based off a monthly compounding, throwing the APY out of tolerance.

My question is, what is our responsiblity to cure the violation? Do we have to figure out every affected CD, and pay extra interest equal to the wrong APY, or since the rate and the terms were correct on the CD, does that buy us some brownie points?

Thanks

You have APY disclosure violations. As long as you paid interest based on the contact terms - there is no reason to atttempt any cures.

RL,
You wouldn't rather provide the cure to eliminate the APY disclosure violation? If you pay the interest at the stated APY there is no violation. I guess I would want to know at least an estimate of how much it would cost to cure.
Just curious.

There are no regulatory based "cures" under Truth-in-Savings. There is no civil liability either.

I need help on a similar situation - we disclosed the CD stating interest would be compounded at maturity, but we paid interest monthly so the APY was disclosed higher than it really should have been since it's not compounded at maturity. How to fix?

If the disclosure was accurate based on the account description, the fact that you have allowed the customer to take monthly payouts does not affect the accuracy of the APY. And, as Randy said just above your post, there's no "cure" for this non-problem, anyhow. If you see something that needs fixing so it won't happen again, go ahead and clean up procedures. But as for this account, drop the matter, and move on to something worthy of concern.