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#681645 - 02/07/07 02:41 PM TIS Compounding
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
I know that when a customer chooses to have their CD interest credited to their DDA account, we still disclose the APY as though the interest remains on deposit and compounds. My questions is what about the compounding and crediting? If we typically compound and credit annually, but the customer wants to have their interest paid out, do we have to change how the compounding and crediting is disclosed? So, in this case, the compounding would be N/A and the crediting would be "annually to DDA XXXXX"? What are others doing?

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Operations Compliance
#681684 - 02/07/07 03:11 PM Re: TIS Compounding MN Banker
homestar Offline
Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
We disclose it with compounding and crediting and rely upon 230.4(b)(6)(iii). We've never been challenged by examiners.
_________________________
"If you want to tell people the truth, make them laugh, otherwise they'll kill you." ~ Oscar Wilde

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#683134 - 02/08/07 07:08 PM Re: TIS Compounding homestar
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Here's an excerpt from our Advanced Deposit Operations Manual on this exact topic. Specifically, you'll want to look at the last 3 paragraphs - an illustration of your question:
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Compounding vs. Crediting:

Compounding occurs when the interest earned on an account begins to earn interest itself. The frequency of compounding is the frequency in which interest that has been earned is added to the balance of the account (principal). Whether the earned interest is or is not available for withdrawal is of no consequence to the compounding frequency.

Crediting is the process of making interest that has been earned available for withdrawal. The frequency of crediting is the frequency with which that process occurs. Whether or not interest begins to be earned on the interest that becomes available for withdrawal is not a factor.

Crediting of interest and compounding of interest are separate and distinct functions.

The greatest confusion about crediting and compounding occurs on time deposits disclosures where, at the customer’s request, interest is paid periodically to the customer either by check or by credit to another account.

Assume a time deposit on which interest is normally compounded and credited quarterly; however, at the customer’s election, the bank will transfer the earned interest to the customer’s saving account monthly. For the customer who elects that option, his or her disclosure must state monthly crediting, not quarterly crediting. A disclosure must describe the customer’s specific account, not the way an account of that type is normally processed.

The real confusion in this instance is the disclosure of compounding. The compounding frequency must be disclosed as quarterly. But, you are thinking, because interest is paid from the account monthly, it never compounds and the disclosure must be specific to the account. You are right and wrong. Compounding and annual percentage yields are disclosed on the assumption that the customer will leave the interest in the account until maturity. This is true even though you know the assumption is wrong. These are the two exceptions to the specific-to-the-account rule. Even though the customer has signed a request that the interest earned be sent to them by check monthly, the compounding frequency and APY disclosed must assume that interest is not withdrawn from the account until maturity. The only exception is when bank requires a customer to withdraw credited interest.

*Compounding = bank policy
Crediting = customer specific
_________________________
David Dickinson
http://www.bankerscompliance.com

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#683393 - 02/08/07 08:32 PM Re: TIS Compounding David Dickinson
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
Wow that's awesome - thank you!

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