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#2258881 - 08/27/21 07:41 PM Regulation DD Error Resolution?
YHWB Offline
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If there are errors found in the calculation of interest paid as well as the APYE, is the an error resolution process like with Reg Z? What notices must be provided to the customer?

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#2258885 - 08/27/21 08:01 PM Re: Regulation DD Error Resolution? YHWB
Andy_Z Offline
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TISA has not changed a lot. This may help.

https://www.bankersonline.com/qa/tisa-new-account-disclosure-error

To a large degree it depends on the violation and if it is one where the bank failed to meet a contractual obligation. As an example "We will pay you X% APY on this account" but the programmed rate did not do that, the bank would need to pay that up and make the consumers whole. To not do that violates Reg DD and UDAP/UDAAP as well as other laws and Regs I'm sure, contracts, advertising, etc.
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#2258887 - 08/27/21 08:08 PM Re: Regulation DD Error Resolution? YHWB
YHWB Offline
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So making interest paid corrections, corrects the issue, without any particular notice requirement? And the AYPE's on prior statements can't be "cured".

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#2258910 - 08/30/21 02:20 PM Re: Regulation DD Error Resolution? YHWB
John Burnett Online
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Correct. If a lot of customers were affected, regulators will want to review your discovery process (which accounts were affected and how far back did you go, etc.) and determine whether this was a single event or there are multiple such errors (for example, if caused by entering an incorrect interest rate into your system's parameters, did it happen only once, or have such errors occurred several times, what your internal controls are to verify system inputs, etc.). If it happens sporadically, it could reflect badly on your compliance controls generally.

As far as notice is concerned, it's generally good form to explain why a correcting entry is made to the customer's account (or why you have sent a closed account customer a check). If nothing else, transparency here can avoid a series of phone calls asking for an explanation of the adjustment from customers who pay attention to their account activity.
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#2258927 - 08/30/21 04:26 PM Re: Regulation DD Error Resolution? YHWB
YHWB Offline
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Joined: Apr 2005
Posts: 587
Out there
Thank you Andy and John.

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