[mbmills]

Yes, we do use a provider for our TIS disclosure. With this CD special, the advertised APY was 2.50%. However, if the customer elected to receive the interest quarterly or semiannually, the APY calculated on the disclosure was 2.49%. For “Compounding and Crediting Frequency,” the disclosure was conditioned to say the following (in addition to indicating that the APY assumes interest remains on deposit):

Interest will not be compounded on this account. Interest will be mailed to you by a check quarterly.

However, based on research, I was thinking that we still need to disclose that interest will be compounded monthly, but paid out at the frequency elected by the customer. And the APY would still be disclosed as 2.50% since it assumes interest is not withdrawn until maturity.

It’s been a little confusing for staff and customers to have seen an advertised APY of 2.50%, but only see 2.49% on the TIS disclosure. We just want to be sure we are disclosing correctly. With deposit rates being low for so long, we hadn’t seen this issue until we ran the higher rate special.

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