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#2277943 - 11/15/22 11:25 PM Reg DD Advertising - Compounding and Crediting
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,266
For our CDs, we compound interest daily and credit quarterly. I know a statement is required in the initial disclosure, but is it required on advertising? In the citing below, I've included (i) and (ii) in my ad, but (iii) is confusing me. I don't think it applies, since we are compounding??

Regulation DD - 1030.8(c)(6)

(6) Features of time accounts. For time accounts:

(i) Time requirements. The term of the account.

(ii) Early withdrawal penalties: A statement that a penalty will or may be imposed for early withdrawal.

(iii) Required interest payouts. For non-compounding time accounts with a stated maturity greater than one year that do not compound interest on an annual or more frequent basis, that require interest payouts at least annually, and that disclose an APY determined in accordance with section E of Appendix A of this part, a statement that interest cannot remain on deposit and that payout of interest is mandatory.

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#2277989 - 11/16/22 09:37 PM Re: Reg DD Advertising - Compounding and Crediting Mel in WA
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
That item only applies to "non-compounding time accounts with a statement maturity of more than one year, that do not compound interest on a yearly or more frequent basis, and the financial institution requires that interest be paid out at least annually (if they didn't require it, the APY would be smaller than the interest rate).

So if you are not advertising such a time deposit, paragraph 1030.8(c)(6)(iii) doesn't apply to you.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2277992 - 11/16/22 11:07 PM Re: Reg DD Advertising - Compounding and Crediting Mel in WA
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,266
Thanks for confirming, John!

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