Compliance Alliance Question of the Week

Question:
Under Reg. DD, if a time account product is advertised generally is there a requirement to provide the term for CDs if a specific CD product is not advertised, and instead, simply that time accounts are among products offered? 
Answer:
No, you’re not required to provide the time requirements in 1030.8(c)(6)(i) when you are only advertising CDs generally and not a specific product. The time requirements are required when you are advertising a specific Annual Percentage Yield (or a bonus which would trigger the APY). If you advertise the APY, it is considered a “trigger term,” which requires you to provide all of the required information in 1030.8(c), as applicable. Since you are only advertising a general product and no APY, the time period requirement is not necessarily required. (c) When additional disclosures are required. Except as provided in paragraph (e) of this section, if the annual percentage yield is stated in an advertisement, the advertisement shall state the following information, to the extent applicable, clearly and conspicuously:  (6) Features of time accounts. For time accounts: (i) Time requirements. The term of the account. 12 C.F.R. 1030.8(c) https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1030/8/#b
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