If we state in an advertisement that an account pays no interest, do we have to state 0.00% APY? This doesn't seem necessary but it also could be interpreted that we are stating a rate of return. We've run ads both ways and I'd like to make a final determination either way so we are consistent. Any guidance is most appreciated.

Advertising rules in 1030.8 and disclosure rules in 1030.4 state required disclosures "as applicable." If there is no APY because an account is non-interest bearing then you do not have to disclose an APY.

Agreed. I'm not sure why we've had the zeros in ads. It's not required and it isn't very marketing friendly to have a string of zeros.

Thank you for chiming in and helping confirm my thoughts.