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#2160922 - 01/18/18 07:31 PM Lobby Sign
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 198
The FDIC examiner told us we need to include "annual percentage yield" at the bottom of an indoor rate board, I thought that if the rates were advertised inside the bank, as long as we stated APY, that "annual percentage yield" did not have to be included on the board. Thank you in advance for any advice given on this.

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#2160943 - 01/18/18 08:36 PM Re: Lobby Sign Compliance Action Subscriber 1226
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
APY is sufficient. The indoor sign must also contain a statement advising consumers to contact an employee for further information about applicable fees and terms. Tell your examiner to refer to §1030.8(e)(2):

(2) Indoor signs. (i) Signs inside the premises of a depository institution (or the premises of a deposit broker) are not subject to paragraphs (b), (c), (d) or (e)(1) of this section.

(ii) If a sign exempt by paragraph (e)(2) of this section states a rate of return, it shall:

(A) State the rate as an “annual percentage yield,” using that term or the term “APY.” The sign shall not state any other rate, except that the interest rate may be stated in conjunction with the annual percentage yield to which it relates.

(B) Contain a statement advising consumers to contact an employee for further information about applicable fees and terms.
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David Dickinson
http://www.bankerscompliance.com

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#2160950 - 01/18/18 08:59 PM Re: Lobby Sign Compliance Action Subscriber 1226
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If your examiner looks at that section (1030.8(e)(2)) in BankersOnline's Regulations pages, he or she will also see an Editor's note we added to the text explaining why "indoor sign" isn't restricted to signs that can only be read by someone inside the building. See https://www.bankersonline.com/regulations/12-1030-008.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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