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#2146426 - 09/18/17 02:41 PM Reg DD disclosure
Compliance Action Subscriber 1226 Online
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Joined: Sep 2015
Posts: 198
Is it a Reg DD violation to remove the statement "You must maintain a minimum balance of $____ to obtain the disclosed annual percentage yield." By removing that statement, there would not be a requirement to disclose how the minimum balance is determined.

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#2146432 - 09/18/17 02:50 PM Re: Reg DD disclosure Compliance Action Subscriber 1226
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Since this is how it is stated within the regulation I don't see how removing it would not be a compliance violation:


(3) Balance information. (i) Minimum balance requirements. (A) Any minimum balance required to:

(1) Open the account;

(2) Avoid the imposition of a fee; or

(3) Obtain the annual percentage yield disclosed.
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#2146483 - 09/18/17 05:56 PM Re: Reg DD disclosure Compliance Action Subscriber 1226
Monster Offline
Platinum Poster
Joined: Sep 2015
Posts: 500
I agree with Skittles. I've also seen a bank get in hot water for this - always double check the website! smile

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#2146828 - 09/20/17 03:40 PM Re: Reg DD disclosure Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Online
100 Club
Joined: Sep 2015
Posts: 198
OK thank you

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#2197218 - 11/02/18 05:52 PM Re: Reg DD disclosure Compliance Action Subscriber 1226
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
What if there is no minimum balance to obtain the APY? Do you not state it, or do you say 1 cent?

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#2197221 - 11/02/18 06:29 PM Re: Reg DD disclosure Compliance Action Subscriber 1226
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Reg DD § 1030.4(b):
"(b) Content of account disclosures. Account disclosures shall include the following, as applicable:"

Reg DD § 1030.8(c):
"(c) When additional disclosures are required. Except as provided in paragraph (e) of this section, if the annual percentage yield is stated in an advertisement, the advertisement shall state the following information, to the extent applicable, clearly and conspicuously:"

If there is no minimum balance to obtain the APY (the bank will pay interest on any positive balance), you don't need to disclose the balance required to obtain the APY.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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