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#1512259 - 02/18/11 07:21 PM Regulation Z verbiage on DDA Statements
Comply101 Offline
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Joined: Aug 2005
Posts: 223
Has anyone come across a situation where Regulation Z verbiage is included on the back of your DDA periodic statements. If so, do you see any regulatory concerns with this? I can understand how it might be confusing for a consumer but is there any potential violation here?

The verbiage includes a notice that says, "The Annual Percentage Rate and Daily Periodic Rate may vary" and a separate notice that discusses the computation of the "daily balance" and how advances/fees may affect the "daily balance". This seems to be dealing with lines of credit or maybe credit cards. Could this be stemming from the July 2010 changes to Regulation Z?

I have a call into our core processor to discuss why it is on the statement but wanted to see if anyone else had seen this.

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#1512267 - 02/18/11 07:30 PM Re: Regulation Z verbiage on DDA Statements Comply101
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,459
Galveston, TX
Many banks have open-end lines of credit (such as to cover overdrafts) and the open-end periodic statements are printed on the same statement stock. There is no voliation to include this information on the back of a deposit account only statement.
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#1512308 - 02/18/11 07:57 PM Re: Regulation Z verbiage on DDA Statements rlcarey
Comply101 Offline
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Joined: Aug 2005
Posts: 223
I thought it might have something to do with overdraft lines. Thank you for comfirming that there's no risk of violation here.

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