Periodic Statement Revisions Allowed?

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Question:

Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?

Answer:

The disclosure of the interest rate is not required on periodic statements under Regulation DD. I am not sure what you mean by your last statement. If these accounts are variable rate accounts or involved tier rate accounts, then the interest rate optionally included on the periodic statements should not vary from the rates disclosed unless the rate has changed in a manner as described in the original TISA disclosure.