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#697285 - 03/06/07 06:07 PM Advertisements on Rate Sheets
Lee55 Offline
Junior Member
Joined: Apr 2003
Posts: 42
Would placing "get an additonal .10% if you renew your CD" on our customer rate sheet make it a advertisment under Regulation DD?

Our rate sheet is part of our Reg. DD disclosures that we provide to our customers. The above verbiage is meant for existing CD customers; however, since the rate sheet is given to all customers when they open an account, a Non-CD customer may open a CD account based on the verbiage. My recommendation is to include the verbiage on the maturity notices rather than the rate sheet to be clear that it is meant for existing CD customers.

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Operations Compliance
#697809 - 03/07/07 02:18 PM Re: Advertisements on Rate Sheets Lee55
A D Virr Offline
Gold Star
Joined: Oct 2000
Posts: 398
Derry, NH
Your recommendation would work providing the software you use can accommodate additional language. My recommendation would be to insert a separate stuffer or letter to existing account holders. I don't think that it constitutes an advertisement under Reg DD.
_________________________
Allan D. Virr, CRCM,CRP
Compliance Audit Solutions, LLC

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