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Promontory for Broker Deposits to Consumer- Reg DD

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Question: 
Our FI is planning on using Promontory to offer broker deposits to consumers. I have thought that Reg DD, section 1030.4 thru 1030.6 (Account Disclosures)​ apply, however the Agreement and periodic statement don't specifically address by Reg DD the required elements. For example, their Agreement states accrued interest will be credited "at least once each month" vs. a specific frequency, and it does not reference if accrued interest will be paid or not paid if the account is closed, and refers to the APYE as "Statement Period Yield". We have just received communication from the vendor and they are telling us that "A Relationship Institution is a “deposit broker” for purposes of TISA and, as such, is subject only to the advertisement provisions of Reg DD." But they don't even spell out at least once Annual Percentage Yield. Is our FI required to meet all the requirements of Reg DD as if the consumer were opening one or our MMAs?
Answer: 

If your bank is acting as a deposit broker, you are responsible for any ads you produce or publish, and must conform to the advertising requirements of Regulation DD section 1030.8. That will include any mention of the Annual Percentage Yield in an ad. Promontory's agreements are not advertisements.

First published on 01/10/2021

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