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Reg DD states that for Rate Information – the rate should state the “Annual percentage yield” and “interest rate” using those terms.
We have been using Deposit Pro which spells the terms out in the TISA disclosure. The system that we are changing to does not allow much room for tiered account disclosures
Are you allowed to abbreviate APY if we note somewhere that it = the Annual Percentage Rate.
It is stated for Advertisements that
“The abbreviation “APY” may be used provided the term ‘annual percentage yield’ is stated at least once in the advertisement.”
Are you allowed to abbreviate on the account opening Disclosure and the disclosure required upon request?12 CFR 2013.4(b) states:
Content of account disclosures. Account disclosures shall include the following, as applicable:(1) Rate information. (i) Annual percentage yield and interest rate. The “annual percentage yield” and the “interest rate,” using those terms, and for fixed-rate accounts the period of time the interest rate will be in effect.
With that in mind I would be cautious about abbreviating on your disclosures. Work with your vendor and possibly your regulator, if you are comfortable seeking their opinion, prior to implementation to get it right and avoid any issues down the road.
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