We have to disclose an Annual Percentage Yield while advertising checking accounts because we’re offering a bonus.

Because a bonus triggers the APY disclosure, does that in turn trigger the ‘effect of fees’ disclosure under the ‘when additional disclosures are required’ section of Reg DD?

Yes - it has a snowball effect - so to speak.

thank you

Are you saying that when you advertise a bonus on an interest-bearing account, and even if you do not include the rates in the ad, you then have to include the APY and balance tiers?

BUMP!

SkiDoo,
I don't understand your response.

I was just moving your question to the top of the line, because I have the same question as you.

The answer to M&M's question is "yes." Of course, if the account in question is a non-interest earning checking account, there is no APY to disclose. And if there is no APY to disclose, it cannot trigger all the things triggered by an APY.

The commentary states that a sentence such as "Open a checking account and receive a bonus" is ok, but what about "Open a checking account and receive $50"? What if we throw in a generic reference to opening a savings account? Do we need to specify a savings product, and then, also provide the APY and disclosures?