TISA / Reg DD – What is a “trigger” term and if stated, what must I disclose?

Compliance > Advertising / Marketing Misc.
Q:  What is a “trigger” term and if stated, what must I disclose?
 
A:  The annual percentage yield is a “trigger” term.  If the annual percentage yield is stated in an advertisement, the advertisement shall state the following information, to the extent applicable, clearly and conspicuously (unless such information is exempted by the regulation):
 
(1) Variable rates. For variable-rate accounts, a statement that the rate may change after the account is opened.
 
(2) Time annual percentage yield is offered. The period of time the annual percentage yield will be offered, or a statement that the annual percentage yield is accurate as of a specified date.
 
(3) Minimum balance. The minimum balance required to obtain the advertised annual percentage yield. For tiered-rate accounts, the minimum balance required for each tier shall be stated in close proximity and with equal prominence to the applicable annual percentage yield.
 
(4) Minimum opening deposit. The minimum deposit required to open the account, if it is greater than the minimum balance necessary to obtain the advertised annual percentage yield.
 
(5) Effect of fees. A statement that fees could reduce the earnings on the account.
 
(6) Features of time accounts. For time accounts:
 
(i) Time requirements. The term of the account.
(ii) Early withdrawal penalties: A statement that a penalty will or may be imposed for early withdrawal.
(iii) Required interest payouts. For noncompounding time accounts with a stated maturity greater than one year that do not compound interest on an annual or more frequent basis, that require interest payouts at least annually, and that disclose an APY determined in accordance with section E of appendix A of this part, a statement that interest cannot remain on deposit and that payout of interest is mandatory.
 
 
 

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