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#26955 - 08/06/02 06:14 PM TISA - amount to earn APY
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
In TISA disclosures must we disclose amount to earn APY if there is no minimum to earn APY? We do require a minimum opening amount but will pay interest on any amount greater than 0.
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#26956 - 08/06/02 08:47 PM Re: TISA - amount to earn APY
Dave M_TCA Offline
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Dave M_TCA
Joined: Oct 2000
Posts: 682
Wherever my most benevolent em...
I can't find anything that says you don't have to, just that you do, so I disclose the $0 figure, just to make sure that there are no misunderstandings.
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David J Mulkerin, CRCM
All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.

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#26957 - 08/06/02 09:56 PM Re: TISA - amount to earn APY
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
The regulation requires that you disclose "any minimum balance" to obtain the APY, and says that all disclosures are to be made "as applicable." That means "if it don't apply, you needn't supply."

Since there is no minimum balance to earn the APY, you do not need to disclose one, IMHO. But the $0 amount disclosure is not a problem.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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