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#492495 - 02/02/06 03:50 PM Billboard Ad
davidm Offline
100 Club
Joined: Mar 2003
Posts: 119
Management is furious that I am requiring a billboard ad to disclose both tier rates on a deposit product. They only want to post the higher rate. What are the risks to the bank and possibly them personally if they move ahead and only show the highest rate? I want the consequences considered before they move ahead and ignore my requirement.

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#492496 - 02/02/06 05:30 PM Re: Billboard Ad
kw@fnb Offline
100 Club
Joined: Jul 2004
Posts: 135
Beatrice, NE
Rates change so much, I'm curious as to why you would go to the great expense of a billboard for a rate.

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#492497 - 02/03/06 12:25 AM Re: Billboard Ad
Andy_Z Offline
10K Club
Joined: Oct 2000
Posts: 27,542
On the Net
First, you aren't requiring anything. You are telling them what the regulation requires.

Second, the penalties of Reg. DD are the points of initial compliance risk. Then there is managements willful desire to potentially knowingly violate the regulation. Should your next examiner ask "What else have they done this with?" Perhaps your examiners who see this would be more likely to stay an extra few days or a week to look. "If they'd do this on Reg. DD, what about BSA and flood?"

You are being restrictive. You are trying to keep them within the legal boundaries so that they, the bank, and the board are not cited for violations of law or the need to discuss civil money penalties.

Altogether now, "once we practice to deceive..."
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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