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#2213158 - 05/08/19 10:04 PM Reg DD, Interest Rate Sheets, and TISA
KerryVBC Offline
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KerryVBC
Joined: Oct 2007
Posts: 151
Colorado
If a customer comes in and wants to know our interest rates/APY, are we required to give them the full TISA disclosures for every account on the list or can we give them give just the rate sheet on its own? Where in Reg DD does it confirm the answer? We're having a discussment with our compliance auditor on this one.
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Operations Compliance
#2213167 - 05/09/19 11:53 AM Re: Reg DD, Interest Rate Sheets, and TISA KerryVBC
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,572
The commentary to Paragraph (a)(2)(i) of 1030.4 (Reg DD) clarifies this:

"1. Inquiries versus requests. A response to an oral inquiry (by telephone or in person) about rates and yields or fees does not trigger the duty to provide account disclosures. But when consumers ask for written information about an account (whether by telephone, in person, or by other means), the institution must provide disclosures unless the account is no longer offered to the public."

In other words, a request for just rates does not trigger a need to provide all TISA account disclosures and a rate sheet could be provided. That said, keep in mind that if you provide a rate sheet to consumers, this is considered an advertisement which requires all applicable advertising disclosures.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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