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?

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.

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.

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.

Thank you Ken, I appreciate the information.