Skip to content
BOL Conferences
Thread Options
#2075149 - 04/22/16 01:13 PM Reg DD Number of Days Disclosure
TomS Offline
Gold Star
Joined: Jan 2004
Posts: 318
USA
Our deposit account statements for non-interest bearing checking accounts do not disclose the number of days in the statement period as required by section 1030.6(a)(4) of Reg DD. I do not find any exception in Reg DD that says you do not have to disclose the number of days if no interest is paid. Or am I missing something?
_________________________
CRCM, CAFP, DAD

Return to Top
Deposits and Payments
#2075189 - 04/22/16 02:42 PM Re: Reg DD Number of Days Disclosure TomS
#12 Online
Diamond Poster
Joined: Jun 2005
Posts: 1,343
If the statement discloses both the beginning date and ending date of the period, and makes it clear whether the days are included in the period, the number of days is not required.
_________________________
CRCM

Return to Top
#2075245 - 04/22/16 04:38 PM Re: Reg DD Number of Days Disclosure #12
TomS Offline
Gold Star
Joined: Jan 2004
Posts: 318
USA
Thanks for your reply. Our statements disclose the last day of the previous statement period and the last day of the current period, so that doesn't cover us. The statements do have a line item for "Days in Period" but there is no number disclosed. I'm thinking it's a system glitch unless I'm missing some reason as to why it does not need to be disclosed if no interest is paid.
_________________________
CRCM, CAFP, DAD

Return to Top
#2075352 - 04/23/16 02:03 PM Re: Reg DD Number of Days Disclosure TomS
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Somewhere in the bowels of the supplementary information that accompanied the publication of Regulation DD there was a statement that indicated banks were not required to make irrelevant disclosures. I believe the example given was that you are not required to disclose an interest rate of "0.00" or an APY of "0.00%" if the account is not interest bearing.

The purpose for indicating the number of days contained in a statement cycle was to allow the consumer to verify the APYE. If the account is not interest bearing, there is nothing to verify.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2075401 - 04/25/16 01:37 PM Re: Reg DD Number of Days Disclosure Elwood P. Dowd
TomS Offline
Gold Star
Joined: Jan 2004
Posts: 318
USA
Thank you Ken, I appreciate the information.
_________________________
CRCM, CAFP, DAD

Return to Top

Moderator:  John Burnett