[TheBank]

If a rate reduction is given on a consumer installment loans if the consumer sets up automatic payments on the loan from a checking account at our bank, is the deposit requirement disclosure of 1026.18(r) required? We would be requiring a checking account with automatic payments to open that loan with that rate, but we would not be requiring a certain deposit amount be kept in the account. Checking minimum balance to open amounts are $100 for each account though.

For this feature, would we be required by Reg Z to include the phrase “The annual percentage rate does not take into account your required deposit”?

[Author]

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