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#625507 - 10/16/06 07:21 PM Reg E notice of varying amounts
ahou Offline
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ahou
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The bank wants to electronically transfer CD interest to 3rd party banks for our customers. The amt of the transfer would vary, depending on the number of days in the month. We want to use a range of amounts (in lieu of monthly notices). We would have to figure a range of amounts of int for each particular customer, because they would have different rates, balances etc. Isn't that correct?
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#625508 - 10/16/06 08:48 PM Re: Reg E notice of varying amounts
John Burnett Offline
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That rings true to me, ahou. Watch out for long or short first and last periods (some banks issue CD transfers only on one day of the month, and this can create odd first and last months for payments. Then calculate interest for a 28-day or 29-day month (if February will occur in the CD term), and a 31 day month, and you have the high and low end of your disclosure amounts.
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#625509 - 10/17/06 02:48 PM Re: Reg E notice of varying amounts
Andy_Z Offline
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205.10(d) allows the range to be disclosed and notice when the range is not met.

Would you redisclose this if the consumer made a partial withdrawal or new contribution, rather than allow constant notices each time you pay interest?
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#625510 - 10/17/06 03:05 PM Re: Reg E notice of varying amounts
ahou Offline
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ahou
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Yes, I guess you'd have to. I found this version on the net:
"If you authorize us to make regular transfers of earned interest from your CD account, your first transfer will be the amount you should expect each period, varying by no more than 10%, unless you make a significant addition to or subtraction from the principal amount."

I'm not sure whether this would satisfy Reg E requirements. (it would be a lot easier than disclosing an actual range for each customer)
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#625511 - 10/17/06 03:10 PM Re: Reg E notice of varying amounts
Andy_Z Offline
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There is no model form on this. In many cases when a disclosure is required, such as Reg. Z requiring a rate, "prime + 3%" doesn't qualify. In this case, because a range is required, I like the 10% method. But I don't know if making the consumer do the math would qualify. Personally, I would run this by my regulator (and the FRB who "owns" Reg E if they're not your regulator).
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#625512 - 10/17/06 03:30 PM Re: Reg E notice of varying amounts
ahou Offline
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ahou
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Good idea. Thanks Andy.
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