We don't display loan rates on our on-line system.....but want to. Right now, when a customer views the balance of a loan or loans on line, the customer cannot see the current rate on his/her loan(s). So if the customer wants to know, he/she has to phone the bank. Is there any guidance or rules with respect to on-line systems? Can we just display the current loan rate? Do we also have to disclose whether the displayed rate is fixed or variable?

Maybe I wasn't clear with what I'm asking. Our customers can view all of their accounts via our on-line system and the system is capable of also displaying account details such as savings account rates. For loans, management thinks we cannot display the loan rate because there's no way to also show if the loan is a variable rate loan....thus the displayed rate might change from week to week. Is it OK to simply display the current loan rate within the account details. There would be no display of the initial APR because interest isn't computed using the APR.

This would not be considered "advertising," so I think you've got a lot more leeway in what you present. And in a non-advertising context, I don't believe you would be required to indicate whether a loan is fixed or variable, although I applaud your management for wanting to ensure customers aren't misled or confused.

Perhaps you could have some sort of generic message down at the bottom of the screen saying, "If you have a variable rate loan, the interest rate shown may be subject to change. Check your loan docs."

If that doesn't fly, you should at least be able to do something by loan product; e.g., all your HELOCs and all your credit cards are variable rate, or all your vehicle loans and all your home equity loans are fixed?

Sounds too simple, but it works for me. Good luck.

Thanks for your opinion, Way Out West. I was beginning to think that my bank is the only bank with an on-line banking system! Our problem is that we can turn the rate on or off globally, but not by product....and the software won't allow the display of a wordy message. However, I did get them to say that they think they can change the word "rate" to "current rate." I would be happy with that!

I would have thought you wanted the opportunity to talk to the borrower and open the dialogue for another loan. But if your reasoning is one of disclosure, I don't know what rules would apply. As noted, it isn't advertising so you are not facing restrictions there. You have already made the complete disclosure once. It might be that you want some identifier such as current or original on the rate.

The only additional thought is to remind your customer contact staff how to handle questions or complaints from depositors who don't understand the difference between the previously disclosed APY/APR and the simple rates in effect from time to time.

Thanks everyone!!!