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#2238828 - 06/30/20 04:10 PM tiered interest rates on TISA disclosures?
SmallBank3 Offline
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Joined: Nov 2019
Posts: 57
Do any of you include the tiered interest rates on TISA disclosures for interest bearing accounts? We are re-doing ours and currently do not.

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#2238829 - 06/30/20 04:14 PM Re: tiered interest rates on TISA disclosures? SmallBank3
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
If you pay tiered interest rates on a deposit account - how in the world can you not disclose it as such?
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#2238832 - 06/30/20 04:31 PM Re: tiered interest rates on TISA disclosures? SmallBank3
Skittles Offline
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Skittles
Joined: Sep 2002
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TN
Are you attaching a current rate sheet by chance?
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#2238842 - 06/30/20 06:02 PM Re: tiered interest rates on TISA disclosures? SmallBank3
SmallBank3 Offline
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Joined: Nov 2019
Posts: 57
We do a rate sheet separately - just curious the pros and cons and what others may do. I would rather update a rate sheet than all the different disclosures.

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#2238843 - 06/30/20 06:06 PM Re: tiered interest rates on TISA disclosures? SmallBank3
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
There is no requirement that the TILA disclosures be in a single document. Many banks use rate sheets for the APY disclosure portion.

Section 1030.3--General Disclosure Requirements

(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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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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