Regulation DD

In regards to section 230.3 of Reg. DD is states that disclosures are required to use consistent terminology when describing terms or features that are required to be disclosed. Would account information and descriptions found on the Banks website (available for consumers) be held to this requirement? i.e. monthly fees etc. Or would this only be looked at in light of UDAP if the terms are not consistent?

I have seen the FDIC cite banks for Reg. DD violations based on using inconsistent terminology between the initial disclosures, periodic statements and any and all advertising, including that on a bank's website.

Any thoughts on the UDAP side of it?

Why would they cite it as a UDAP when they can tie it to a direct violation of an existing regulation?

Well, our thought is that UDAP is being looked at in every aspect of banking, even where you least expect it! So it could possibly be cited as a Reg DD AND UDAP violation. That is why I'm questioning it. I want to make sure that all the bases are covered and that I'm not miss interpreting anything.

Well I guess if the website was worded in a manner that was deemed outright deceptive, than you could face a UDAP violation also. But if you were just referring to a "monthly service charge fee" rather than a "monthly fee", which not might be consistent under Regulation DD, I would be hard pressed to see how that would be a UDAP.

BabyB, you may want to read ABA's magazine when it comes out. There is a nice article about the longer reaching arm of UDAP.