Answer:
Randy Carey
The answer is no and no.
Answer:
Andy Zavoina
While the question may come up, "why not offer it to everyone" your criteria and expectations should answer that question. The deposit side of the bank doesn't have a fair lending equivalent but I like to think most banks follow a "fair banking" doctrine so I would ensure you'd have an answer to that question.
As to rate boards, to expand on Randy's answer Reg DD doesn't require them. If you have them there are rules as to what is shown but in many banks it isn't practical to assume every product is listed. So excluding one or more of the less commonly used accounts is not an issue.
Answer:
John Burnett
What you DO have to have is the ability to crank out a disclosure on request and one prior to opening an account for each personal, family or household purpose account you offer. And that will require selecting an interest rate for these bid-rate accounts for the purpose of on-request disclosures, and using the correct interest rate and APY for account disclosures.
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