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#1843399 - 08/16/13 09:33 PM Truth in savings- Tier rates
Dodge Offline
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Joined: Mar 2010
Posts: 267
We are doing a CD special with tier rates. I read Appendix A to Regulation DD and the Tiering Method we are following is A. So, the TIS will read as followed:
- $1,000 to $100,000 1.80 interest rate with 1.82 A.P.Y
so and so

The problem is all that verbiage does not fit in the in appropriate section of the Truth in Savings disclosure. I was wondering if we could state "see additional terms" and then disclose all it under the additional terms?

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#1843427 - 08/16/13 10:21 PM Re: Truth in savings- Tier rates Dodge
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,353
Galveston, TX
I'm confused - how can you have a CD with tiered rates??? A CD is usually opened for a specific dollar amount unless you are allowing additional deposits.
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#1843450 - 08/17/13 12:51 AM Re: Truth in savings- Tier rates Dodge
Dodge Offline
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Joined: Mar 2010
Posts: 267
Tiered CD rates is very new me, and maybe I didn't explain it well or maybe this is an off the wall idea.

If a customer opens a CD for $50,000 (1st tier opening balance falls on or in between $1,000 to $100,000) then the customer will receive the 1.80% interest rate.

If someone opens a CD for $150,000 (2nd tier opening balance fall on or in between $100,000 to $250,000 then they will get the next tier rate 1.90%).

Let me know if we are way off course, but I thought that's how it worked. However, like I said before this is new to me.

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#1843463 - 08/17/13 11:01 PM Re: Truth in savings- Tier rates Dodge
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,353
Galveston, TX
Those are not tiered rate accounts. They get the "one" rate that they qualify for at account opening. You only disclose one rate in your TISA disclosure.
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#1844310 - 08/20/13 08:48 PM Re: Truth in savings- Tier rates Dodge
BuckDog Offline
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Joined: Jun 2006
Posts: 123
Tennessee
We have tiered rates on our Money Market Accounts. You are right the disclosures needed will not fit in the box so we created an additional disclosure sheet that prints out for our Money Market Accounts. It's one sheet that shows $1000 - 4,999, rate X.XX with APY X.XX; 5,000 - 49,999, rate X.XX with APY X.XX. etc....

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#1844371 - 08/21/13 12:41 PM Re: Truth in savings- Tier rates Dodge
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The TISA disclosure for such a CD would include only the rate information pertinent to the particular account. An ad for the CD would include all the tiers.
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