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#2213497 - 05/14/19 12:46 PM Customer Requested TIS
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
1030.4(a)(2)(ii)(A) - In providing disclosures upon request, the institution may: Specify an interest rate and annual percentage yield that were offered within the most recent seven calendar days; state that the rate and yield are accurate as of an identified date; and provide a telephone number consumers may call to obtain current rate information.

Our system doesn't appear to have a way to print a TIS pursuant to a customer request, we can only obtain one if we go through the steps of opening an account.

As an alternative, we have a folder with a TIS for each account available for a CSR to get the disclosure when needed (btw - no one ever asks us for a TIS). The folder is updated with a new TIS every time a rate changes.

The disclosure on the TIS reads - The rate(s) and annual percentage yield(s) disclosed above were offered within the most recent seven calendar days and were accurate as of 04/24/2019. To obtain the current rate(s) and annual percentage yield information, please call XXX.XXX.XXXX.

Since our rates do not change often, the rate will in fact be one we offered in the most recent seven calendar days, but the process we have means that the accurate as of date could be a date from months ago.

Will this be a problem since the rate and APY are accurate and are those offered within the most recent seven calendar days?

Thanks in advance.
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Operations Compliance
#2213507 - 05/14/19 02:00 PM Re: Customer Requested TIS Likes to Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
Since no one ever requests them - why not have blank forms available and just write in the current interest rate and APY when you hand it to the person that never requests one?.
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#2213509 - 05/14/19 02:07 PM Re: Customer Requested TIS Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
I like that idea. Thanks.

But would we be out of compliance with the current process because of the accurate as of date being older even if the rate is current?
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#2213510 - 05/14/19 02:10 PM Re: Customer Requested TIS Likes to Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
Not sure why you need an as of date on a TIS disclosure. It is not an advertisement.
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#2213519 - 05/14/19 03:02 PM Re: Customer Requested TIS Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,060
In the mountains
Both our old system and this new one put a date on the TIS (which is the date it is being printed) and has that the rates are accurate as of that date. Old system used Wolters Kluwer forms and this new one uses CSI forms. We don't have any ability to change this.

We can probably pull the TIS into adobe and remove the date and the rate and APY and replace with blanks that the CSR can fill out manually, but I don't want to suggest this if there really isn't a compliance issue with what they are currently doing - if the date isn't an issue.
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