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#1699874 - 05/15/12 08:27 PM Trigger Term
cbailey Offline
Member
Joined: Jan 2004
Posts: 67
We have stated an APY for a CD promotion ad. The CD does not have any maintenance or activity fees tied to the account, except the early withdrawal penalty. Would the early withdrawal penalty be considered a maintenance fee? Is the statement "fees may reduce the earnings on the account" required?

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#1702443 - 05/23/12 03:34 PM Re: Trigger Term cbailey
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,450
Somewhere
IMO, no. We do not include "fees may reduce earnings" verbiage on an ad for our CD's.

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#1702471 - 05/23/12 04:11 PM Re: Trigger Term cbailey
Bob The Banker Offline
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Bob The Banker
Joined: May 2010
Posts: 958
You would have to state that an early withdrawal fee applies per Reg DD, however, upon inspection of the sample advertisements in the language I agree with P*Q that "fees may reduce earnings" is not required if no other fees are applicable.

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#1706434 - 06/04/12 10:07 PM Re: Trigger Term cbailey
cbailey Offline
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Joined: Jan 2004
Posts: 67
Great, thank you for your input.

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