Skip to content
BOL Conferences
Thread Options
#2282805 - 03/29/23 08:27 PM TISA Disclosure-Minimum Balance to Obtain APY ???
complynewbie13 Offline
100 Club
Joined: Dec 2014
Posts: 154
Minnesota
I am reviewing TISA requirements and do not understand something. 1030.4(b)(3) says that we need to disclose the minimum balance required to obtain the APY. If it is a tiered account, where the rate is different depending upon the account balance, how would we disclose this? The APY would be different for each tier? Is this only required on an account with no tiers?

I did look at the regulations sample forms, and I see that variable rate money market account (form b-9) does not have this disclosed, but a sample CD (form b-7) does have a sentence that says "You must maintain a minimum balance of $1,000 in your account every day to obtain the annual percentage yield listed above." If this is the key, is the minimum balance, the balance it takes to open the account - such as only being able to open a cd for $1,000 or more. For example, if a customer was opening up a $5,000 CD, the TISA disclosure would still state "You must maintain a minimum balance of $1,000 in your account every day to obtain the annual percentage yield listed above."

Thanks!

Return to Top
Deposits and Payments
#2282810 - 03/29/23 10:06 PM Re: TISA Disclosure-Minimum Balance to Obtain APY ??? complynewbie13
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,724
Illinois
Look at the commentary to 1030.4(b)(1)

3. Tiered-rate accounts. Each interest rate, along with the corresponding annual percentage yield for each specified balance level (or range of annual percentage yields, if appropriate), must be disclosed for tiered-rate accounts. (See Appendix A, Part I, Paragraph D.)
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top

Moderator:  John Burnett