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#2140826 - 08/04/17 04:00 PM TISA Disclosure on Checking Accounts
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
I understand that a TISA disclosure is necessary for a checking account and that "as appropriate" applies as to what is disclosed...my question is, what is appropriate. Should one have a statement that the account does not earn interest? Is it basically just a disclosure as to what the fees associated with the account are? If anyone would like to share what they have used as a TISA disclosure for a checking account, that would be helpful too.
Thanks!
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#2140987 - 08/07/17 02:22 PM Re: TISA Disclosure on Checking Accounts Bec
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,864
Cape Cod
There's no requirement that you disclose the fact that the account does not earn interest. For the same reason, you need not disclosure an APY for the account. You are correct in your statement that most of the disclosure for such an account is a list of account-related fees and the conditions under which they may be imposed (or under which conditions they won't be imposed, as in the case of a minimum balance to avoid a monthly service charge).
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#2141017 - 08/07/17 03:53 PM Re: TISA Disclosure on Checking Accounts Bec
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
In support of that, there is a statement that Regulation DD does not require banks to make "irrelevant" disclosures; e.g. "The APY on this account is 0." I cannot remember whether it's in the commentary or the supplementary information that accompanied the regulation when it was published.
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#2141672 - 08/11/17 01:57 PM Re: TISA Disclosure on Checking Accounts Bec
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
Thank you both, I appreciate it.
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