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.