Need some guidence here:

I am reviewing a multi page piece that marketing is putting together that discusses in general terms the products, services and programs we offer. We are trying to keep it vague enough (i.e. not mention specific loan terms) to reduce the need for fine print,disclosures, and costly reprints.

In the section where we discuss different personal savings options, we are stating as appropriate "...in tiered rate options..." or "...with a low minimum blance requirement..."
We are not quoting any rates or numbers here, just general, light info...something a potential customer can take with them to review and study.

My question: Are these statements enough to require listing minimum balances and monthly fees? Sec 230.8 leads me to say no, but 230.4 is making me think otherwise.

And if so, would including a current fee disclosure insert be sufficient?

As long as you don't mention any one APY, you don't trigger anything else under TISA. If you mention one APY, you trigger all APY's and the corresponding minimum balance for each tier (as well as other disclosures).

Thanks David! Glad to know I was reading too much into it.

I consider it one of my goals to keep the Marketing department as happy as possible, and this certainly helps!

Thought I would pass along a thought for your marketing material preparation: Have you thought about putting this marketing info on a DVD? The cost is significantly lower and more easily engaged by the customer/prospect.