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#2254226 - 05/21/21 05:35 PM Online Account - TISA & Interest Rates
mnbanker09 Offline
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Joined: Jan 2018
Posts: 105
For those that offer online account opening, how do you disclose Rate Information for interest bearing accounts in accordance with 1030.4(b)(1)?

I've discovered that our online TIS disclosure includes rate information, with the statement that rates and APYs are accurate as of {DATE}, call us for more current information. The "as of" date happens to be months ago. Yikes.

Thanks in advance.

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#2254245 - 05/22/21 02:47 PM Re: Online Account - TISA & Interest Rates mnbanker09
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,995
Toano, VA
Originally Posted by mnbanker09
Yikes.
+1
Online rate boards are the easiest (and cheapest?) way to avoid disseminating obsolete (misleading?) information to the public...but here we are. Web content is like children--when you create it, you MUST provide for its care and feeding. :-)
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#2254662 - 05/28/21 07:56 PM Re: Online Account - TISA & Interest Rates Richard Insley
mnbanker09 Offline
100 Club
Joined: Jan 2018
Posts: 105
Agree. I've discovered that the rates disclosed are actually accurate, even though the 'as of' date that is stated is months ago. Is this a violation of Reg DD?

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#2254668 - 05/29/21 12:08 AM Re: Online Account - TISA & Interest Rates mnbanker09
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,995
Toano, VA
Rereading your original question, I realize I gave you an answer to a question you didn't ask! Your "accurate as of..." language sounded more like advertising language--not account-opening disclosures. Someone who's more familiar with the rules for account opening disclosures will have to help you with this. You're beginning in a good place, however, if you know the online offering/opening rates are accurate at the time accounts are opened.
_________________________
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#2254686 - 06/01/21 03:18 PM Re: Online Account - TISA & Interest Rates Richard Insley
mnbanker09 Offline
100 Club
Joined: Jan 2018
Posts: 105
I appreciate any and all feedback Richard, thank you!

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