Billboard Ad

Management is furious that I am requiring a billboard ad to disclose both tier rates on a deposit product. They only want to post the higher rate. What are the risks to the bank and possibly them personally if they move ahead and only show the highest rate? I want the consequences considered before they move ahead and ignore my requirement.

Rates change so much, I'm curious as to why you would go to the great expense of a billboard for a rate.

First, you aren't requiring anything. You are telling them what the regulation requires.

Second, the penalties of Reg. DD are the points of initial compliance risk. Then there is managements willful desire to potentially knowingly violate the regulation. Should your next examiner ask "What else have they done this with?" Perhaps your examiners who see this would be more likely to stay an extra few days or a week to look. "If they'd do this on Reg. DD, what about BSA and flood?"

You are being restrictive. You are trying to keep them within the legal boundaries so that they, the bank, and the board are not cited for violations of law or the need to discuss civil money penalties.

Altogether now, "once we practice to deceive..."