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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