If we open an account without receiving a deposit, our TIS does not show the rate/APY. In order to comply with Reg DD, should we then print off a current rate sheet for the customer to take with them showing all available rates at the different tiers? Or, do we wait until a deposit is made, then send them an updated TIS? I'd hate to have to rely on our frontline staff to remember to print off a separate document from their desktop in these circumstances. Thanks!

What do you do if the deposit isn't made until weeks later and the rates have then changed? I thought most banks wouldn't open an account until the opening deposit is made.

Well Lois, we probably shouldn't be doing it, but in certain circumstances, it does happen. Currently, we produce a deposit rate sheet and give to the customer (or send to customer) when they open the account that shows the rates as of that day. I have heard that other banks enter a minimal amount on the TIS so that it will disclose a rate and APY. Not sure if I am comfortable with that, either!