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Reg DD-Advertising a CD Special on Rate Sheet

Question: 
When advertising a CD special on a rate sheet that will be provided to customers, and the ad only indicates the CD special product name with a statement that says, "ask us how to open your CD special," and nothing else, but the CD special has conditions and limitations that the regular CD accounts do not, should a bank disclose on the rate sheet what those conditions and limits are that differ from the regular CD products that are also listed on the rate sheet? There is a fully disclosed addendum for the special that covers the Reg DD disclosure requirements. However, this will only be provided if the special is opened by the customer. My concern is that if the customer only requests the rate sheet and doesn't open the account the customer will not receive the addendum or the full scope of the special on the rate sheet and this may be a little misleading if the customer comes back at a later date to open the special and they find out there are conditions to be met on the product.
Answer: 

by David Dickinson:

If you don't state the APY (or any Bonus info), you don't trigger anything further. Being unclear is not good (UDAP), but you're not technically triggering any of this. You could add "ask us for more information" on something similar.

Answer: 

by Richard Insley:

Good advice about disclaimer, David. There should be room somewhere on a printed rate sheet to put some of the familiar boilerplate, like: Member FDIC (required), conditions apply, minimum deposit (or term) required, penalty for early withdrawal, product is sold by weight not volume some settling of contents may have occurred during handling, and batteries not included.

First published on 11/10/2019

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