Profile for User: Barbara Boccia

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  • in reply to: Example of effect of interest rate increase #347129
    Barbara Boccia
    Participant

    Under Truth in Savings Regulation DD, advance notice is required for any change that may negatively impact a customer, such as the Annual Percentage Yield (APY) going down, and the change-in-terms information must be provided at least 30 days in advance. (Section 1030.5 Subsequent Disclosures https://www.consumerfinance.gov/rules-policy/regulations/1030/5/)

    While a formal change-in-terms is not required for a rate increase (which positively impacts a customer,) it is customary to let the consumer know the same type of information – including the type/name of accounts impacted, the rate change from and to, and the effective date. Simply stating “by 0.250%” without specific data may be confusing or misleading, depending upon the context, so you don’t want to run into any concerns under Unfair, Deceptive or Abusive Acts or Practices (UDAAP).

    For example,
    The rate on our XXZ Savings Account will be adjusted from 3.75% to 4.00% Annual Percentage Yield (APY), effective 5/01/25.

    • This reply was modified 1 year ago by Brent V.
    in reply to: FDIC Signage #347108
    Barbara Boccia
    Participant

    Let’s look at FDIC 12 CFR § 328.3 (b) (4) – Signs within institution premises and offering of non-deposit products within institution premises:

    “(4) Varied signs. An insured depository institution may display signs that vary from the official sign in size, color, or material at any location where display of the official sign is required or permitted under this paragraph. However, any such varied sign that is displayed in locations where display of the official sign is required must not be smaller in size than the official sign, must have the same color for the text and graphics, and includes the same content.” https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-328/subpart-A/section-328.3

    Based on this, your size of 7×3 is OK. You need to check for that last part of the sentence to ensure you have the same content and “in the same color for the text and graphics.” So, if the graphics are black, the lettering text must be black. Assuming the silver is in the background (replacing gold) you should be OK there.

    This also aligns with the FDIC FAQ re #4:

    “The final rule does not modify color requirements for the physical FDIC official sign. The rule continues to require use of the standard, in-branch official FDIC sign, which is 7×3 inches in size with black lettering and gold background. Upon request, the FDIC will continue to provide the official sign at no cost to IDIs. As has been the case traditionally, IDIs may, at their expense, procure from commercial suppliers signs that vary from the official sign in size, color, or material. An IDI may display signs that vary from the official sign in size, color, or material at any location where display of the official sign is required or permitted. However, any such varied sign that is displayed in locations where display of the official sign is required must not be smaller in size than the official sign, must have the same color for the text and graphics, and include the same content. 12 CFR § 328.3(b)(4).” https://www.fdic.gov/deposit-insurance/questions-and-answers-related-fdics-part-328-final-rule

    • This reply was modified 1 year ago by Brent V.
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