We are struggling as to when a full disclosure from our origination system should be provided versus a rate sheet. If a consumer inquires about rates, it seems acceptable to provide a rate sheet that includes tiers and APYs for each account. At what point would a consumer need the full TISA disclosure (rates, tiers, minimum balance, compounding and crediting, etc.)? Do they have to ask about the features of a specific account?

Our rate sheets are for internal use only and are not handed out to customers. It was always my understanding that once you hand the rate sheet out to a customer, it then becomes an advertisement and you would be required to provide additional disclosures as stated in Reg DD. If a customer is asking for something in writing that provides rates for certain products, I would provide them with the full account disclosure.

Our rate sheet includes all the disclosures required for an advertisement on the back. Would it be safe to say that full disclosures needs to be provided if the consumer specifically asks for something in writing?

Providing a rate sheet the includes appropriate information to comply with advertising requirements seems appropriate if a consumer asks for information on your bank's rate(s). But if I asked for consumer information about your NOW account(s), you should provide account disclosures for your NOW account(s).