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#1117633 - 01/27/09 05:43 PM CD Renewals
Compliance4521 Offline
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Compliance4521
Joined: Jan 2007
Posts: 533
Washington
Maturity notices are mailed to our customers along with required account disclosures. since we do not know the rate at time of notice we provide a date and phone number for them to call and get the rate.

We also send the customer a notice after the rate has been established. Since this notice is not required under Reg. DD, do you think it is OK that we only include the Interest Rate of the CD?

I am thinking yes it is, but am interested in others?

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#1117759 - 01/28/09 01:08 AM Re: CD Renewals Compliance4521
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,390
Galveston, TX
I would cancel the second notice and save money as have 90% of the other banks. It is not advertisement or disclosure required by the regulation, so it would not be governed by any disclosure requirements.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1118212 - 01/28/09 06:39 PM Re: CD Renewals rlcarey
Milby Offline
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Joined: Apr 2007
Posts: 953
Tejas
I agree with rlcarey. No point in the expense of the notice. But if you are gung-ho on sending it, why wouldn't you include the APY? Customers understand what APY means, so why not use it consistently?

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#1227591 - 08/05/09 04:16 PM Re: CD Renewals Milby
MHuff Offline
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MHuff
Joined: Nov 2006
Posts: 219
LA
I have a similar question. Our maturity notice states that the interest rate and APY have not been determined and includes all the required disclosures. I've been asked if we can include an insert with the maturity notice that gives the current APY only and not include the interest rate. They believe that some of our customers get confused by having both the I.R. and the APY listed on our rate sheet (which we don't send with the notices).

Can we include an insert with just the APY?
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#1227605 - 08/05/09 04:28 PM Re: CD Renewals MHuff
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,390
Galveston, TX
Has the rate been determined or not. Why would you insert the "current" rates?

You have to disclose both:

(b) Content of account disclosures. Account disclosures shall include the following, as applicable:

(1) Rate information--(i) Annual percentage yield and interest rate. The ``annual percentage yield'' and the ``interest rate,'' using those terms, and for fixed-rate accounts the period of time the interest rate will be in effect.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1227635 - 08/05/09 04:51 PM Re: CD Renewals rlcarey
MHuff Offline
100 Club
MHuff
Joined: Nov 2006
Posts: 219
LA
Thanks, I agree. Just wanted confirmation on my thoughts. I believe it would cause even more confusion to include an insert with rate(s) that may or may not be accurate at maturity.
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CRCM

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