You must disclose the amount of interest earned during the statement period, even if not credited. See the commentary to section 230.6(a)(2). If I read your question correctly, if I had an account with you, I'd receive a statement as of the 15th of each month but you'd post (credit) interest only at quarter ends. That means that two of each quarter's statements would not show any interest paid (the statements cut on 2/15 and 3/15, for example). Each monthly statement would show the amount of interest earned (accrued) during that statement period only. The statement cut on 1/15 would show two interest figures -- the larger, labeled "Interest paid," would be posted on 12/31 and reflect a quarter's worth of interest. The smaller number would be for the statement period only, including 12/16 through 1/15, inclusive, and would be labeled something like "Interest earned."
Last edited by John Burnett; 05/15/08 07:42 PM.
And, of course, the APYE will be based on the earned interest.
That, as you may imagine, will be potentially even more confusing for your customers than it is for you!
Oops -- If you've read this far and are scratching your head because you recall a special rule for quarterly crediting and monthly statements, you're right. See the two posts just below.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8