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APY Disclosure Requirement for a Bonus

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Question: 
We are advertising a $125 bonus that will be paid when a customer completes a few requirements, including opening 1 of 3 various non-interest and interest-bearing checking accounts, signing up for a direct deposit, and using our mobile banking app. I wasn't planning to disclose an interest rate or APY to avoid the additional disclosures caused by the trigger term. However, when disclosing a bonus, the APY appears to be a requirement. I wanted to verify that we have to disclose the APY (using the term annual percentage yield) and the additional disclosures caused by this trigger term if we are disclosing a bonus. Or, does the APY disclosure requirement for a bonus not apply if we were not planning to disclose the interest rate or APY? Also, are we required to use the word "bonus" in our ad?
Answer: 

If you promote a bonus, you trigger the following:
1. APY [and therefore all of the other requirements that are triggered when you mention an APY];
2. Time required to earn the bonus; and
3. Minimum balance required to earn the bonus.

So whether you planned to disclose the APY or not, you must I you promote a bonus. You are not required to use the word "bonus."

First published on 12/01/2019

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