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#2235670 - 04/24/20 08:09 PM Online Deposit Account Opening - TISA
Christina the Auditor Offline
Member
Joined: Sep 2006
Posts: 89
Does it work to say "Rate is disclosed at time of account opening. Please contact us at XXX for additional rate information" for deposit accounts we are opening online? Truth in Savings says you need to disclose interest rate and APY. Can we do it this way? Or does it actually need to be written out on the TISA itself?

Thank you!

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Deposits and Payments
#2235672 - 04/24/20 08:13 PM Re: Online Deposit Account Opening - TISA Christina the Auditor
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
The TISA disclosure must be "in writing in a form the customer may keep" A phone call doesn't meet that requirement. The interest rate/APY must be on the TISA.
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#2237008 - 05/20/20 03:26 PM Re: Online Deposit Account Opening - TISA Christina the Auditor
Angela Offline
Junior Member
Joined: Sep 2014
Posts: 31
I would like to add to this question please. For online account opening, if we state in our TIS "please refer to our rate sheet for the interest rate and annual percentage yield (APY) on this account." and then we include our rate sheet with the TIS, is this sufficient?

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#2237018 - 05/20/20 03:51 PM Re: Online Deposit Account Opening - TISA Christina the Auditor
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
1030.3(a) Form.

1. Design requirements. Disclosures must be presented in a format that allows consumers to readily understand the terms of their account. Institutions are not required to use a particular type size or typeface, nor are institutions required to state any term more conspicuously than any other term. Disclosures may be made:

i. In any order.

ii. In combination with other disclosures or account terms.

iii. In combination with disclosures for other types of accounts, as long as it is clear to consumers which disclosures apply to their account.

iv. On more than one page and on the front and reverse sides.

v. By using inserts to a document or filling in blanks.

vi. On more than one document, as long as the documents are provided at the same time.
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#2237036 - 05/20/20 05:12 PM Re: Online Deposit Account Opening - TISA Christina the Auditor
Angela Offline
Junior Member
Joined: Sep 2014
Posts: 31
Thank you!

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