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#628036 - 10/23/06 05:56 PM "Only one tier is advertised"
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 293
Southern State
Compliance vs marketing again.... if we are advertising a money market account and we have various tiers available but our ad is only about one particular tier, do we have to list all other possible tiers, minimum balances, and APY?
Opinions are mine and subject to change frequently

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#628037 - 10/23/06 07:36 PM Re: "Only one tier is advertised"
GuitarDude Offline
Power Poster
Joined: Nov 2004
Posts: 5,924
So Cal
All tiers must be included. Here is an excerpt from the commentary to Reg DD section 230.8:

(b) Permissible rates
1. Tiered-rate accounts. An advertisement for a tiered-rate account
that states an annual percentage yield must also state the annual
percentage yield for each tier, along with corresponding minimum balance
requirements. Any interest rates stated must appear in conjunction with
the applicable annual percentage yields for each tier.
I've just writed a wrong.

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#628038 - 10/24/06 12:34 PM Re: "Only one tier is advertised"
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Banks with tiered rate accounts often include the most attractive rates in the body of the ad, and list information about the other tiers in the mouseprint. But all tiers must be included somewhere in the ad.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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