I believe rate boards are considered "indoor signs" under Reg DD, therefore the only disclosures needed are to disclose the "APY" and a statement to contact an employee about applicable fees and terms.

My question is do we need to disclose that an early withdrawal penalty may apply if we're advertising CDs? I always thought it was needed, but I can't seem to find anything to support that.

Thanks!

Lobby Boards

When the Federal Reserve Board published the final Truth In Savings regulation, it included a partial advertising disclosure exception for lobby rate boards. This exception excluded all other signs,
such as in-bank banners, point-of-sale advertisements or other types of signs. Thus, all in-bank signs except lobby boards were required to have every appropriate disclosure.

Required Disclosures

The Housing and Community Development Act, signed into law in October, 1992, broadened the in-bank sign exemption. Now, all in-lobby rate boards facing inward need only show the following if a
rate or yield is referenced:

1. Annual Percentage Yield.

2. Statement: Request further information from an employee concerning the fees and terms applicable to the advertised account.

Consequently, banners, posters, point-of-sale displays and lobby boards need only disclose these two items to comply with the advertising rules in Regulation DD.

Consumers requesting more information after viewing a lobby board must receive an account disclosure at the time of request.

Outward Facing Signs

Lobby boards and signs placed primarily for viewing by the public rather than consumers inside the institution are not exempt from the advertising disclosure provisions. These rate boards or displays
must include all of the regular advertising disclosures. The Federal Reserve Board's opinion is that consumers outside the institution are less likely to come in and request an account disclosure and
therefore, depend on the displayed information when shopping for products. For instance, a rate board facing the street is considered an outward facing rate board.

At times it will be difficult to determine whether a lobby rate board or sign set at an angle is designed only for interior viewing because street traffic also may be able to view the lobby board from
outside. Having the inside designation is most advantageous; fewer disclosures are required, so more emphasis can be placed on selling products.

If a lobby board faces inward during the day and outward after hours, include all the required disclosures for public viewing. The designation of a sign as in-lobby or external will be subjective.
Compliance examiners may take a conservative approach; if there is any doubt about a sign's placement, it would be best to include all of the applicable advertising disclosures.

lll Compliance Note Compliance examiners may make a subjective judgment call when determining if a rate board is facing inward or outward. Be prepared to support the institution's
designation.
-I'm working on the same stuff today-hope this helps

Thank you so much! Can you tell me where you got this?

I subscribe to something called the CCH-(a Wolters Kluwer business -support.cch.com) It's updated monthly via CD which lives in my computer. If I could only have one reference source, this is the one I would not give up! Yes-I think its that helpful.

Is it the Banking Compliance Library, because I have that too! Where did you find it on there?

I agree - it's the best thing ever invented!

Its under Advertising;Advertising;Truth in Savings;Lobby Boards.

I didn't know banks still had lobby boards, I thought those went out in the 90's. Hmmmm....