When advertising time deposit rates with a bump rate feature, what all is required?
Also how do you disclose a rate ceiling, as a rate or APY?
With interest rates paying below 1% on deposit accounts, interest rate and APY is the same for most of our deposit accounts opened. Is it required to test APY for new deposit accounts or can we just test deposit statements? I work in compliance monitoring and I do not see the point of testing new account disclosures where the interest rate is the same as the APY paid. I'll appreciate you guidance.
Is GAP insurance an APR fee? Sometimes we add GAP insurance premiums to our auto loans. It is a flat fee that the customer has the option of purchasing. If they purchase it, the loan amount is increased to include the fee and we pay the insurance company from the proceeds.
We are doing a real estate mortgage marketing radio ad and are stating an interest rate and APR. How far out do these rates need to go? Is two places far enough, or do we need to go three as in 4.677%? We'll also be advertising deposits. Do those rules differ as to APR/APY and the decimal places that should be disclose?
Regulation DD Commentary Stays "As-is"
Checklist C: Advertising
Determine the types and extent of advertising within the control of the institution. Confirm that:
Auditing For Truth-In-Savings
by Phil Gay
Inclusion and accuracy of APY and interest rate
For stepped and tiered rate accounts, all applicable APYs and interest rates