Description
“The truth, the whole truth and nothing but the truth.”
This is more than an oath sworn in court. It is also the entire premise behind the Truth In Savings Act: to tell the truth, the whole truth and nothing but the truth about your deposit account products.
Reg DD implements and gives instructions for how exactly to carry out the provisions of the Truth in Savings Act. It is a road map that covers everything from advertising to periodic statements, checking accounts to CDs. It is imperative you know all about it and monitor it regularly for compliance.
Reg D, on the other hand, implements the Federal Reserve Act. It is an entirely different matter altogether, but it often crosses paths with Reg DD, leading to much confusion and exasperation. Why the confusion? Besides the similar names, they both refer to “Deposit Accounts”, “NOW Accounts”, “Time Accounts”, and make mention of withdrawal limitations.
Make no mistake, though, they are very different rules. Good deposit compliance requires you have a great understanding of each and keep them in their proper context.
To stay on the right side of both Reg DD and Reg D, you need to know all the requirements for the entire life cycle of a deposit account. This includes:
- Required advertising disclosures
- Triggering terms
- What can (and cannot) be different for ads in different mediums, including online advertising
- 100% understanding (and calculation!) of the APY
- General disclosure requirements
- Who must get them
- When they must be provided
- Account opening disclosure requirements
- Deposit accounts
- Time accounts
- Eligibility requirements
- Withdrawal limitations
- Special disclosures for overdraft services
- Change in Terms disclosure requirements
- Periodic Statement requirements
- Record retention
- UDAP traps
If you touch deposit compliance in any way, either as a compliance officer, an operations officer, or in customer service, this is crucial information to know and understand. I’ve been on the front lines of compliance for 25+ years, and I’ve lived these things. I’ve implemented and been repeatedly examined on these laws and have the perspective and insight to share!
This two-hour session will give you the practical knowledge to confidently understand all of the “Whys” listed above. Content will be presented in a clear and descriptive manner, complete with regulatory citations to give you the authority to act with confidence!
BACKGROUND:
Reg DD: Truth in Savings Act
This law is all about describing deposit accounts in a truthful way, both in advertising and before account-opening, so that customers may make informed decisions. Later, once an account is open, periodic statements must describe what has happened in the account fully and truthfully, so that customers can understand what is happening with their accounts and know that they are getting what they signed up for. If a change happens, full disclosure must be made too!
Reg DD is firmly a consumer-protection regulation.
There are specific descriptions that must be provided, from the Annual Percentage Yield (APY), to fees and penalties, to any other feature that an account may have.
At any time, if a financial institution doesn’t truthfully describe what can, will, or has happened, consumer harm can occur. We don’t want that. Not only is it bad for business, but it carries regulatory consequences!
Congress never could have imagined the changes to technology (online banking) or society (social media) and the impact they would have on banking. The rules still remain, whether an account is being advertised on an old-fashioned rate board or a tweet.
Reg D: The Federal Reserve Act
This law is all about setting aside appropriate reserves in case there is a run on the bank. If there is a panic, and masses of people flood the institution to take their money out, your institution must have enough liquid funds to service those demands. (Aha! That’s where the name “demand deposit account”, or “DDA” came from!) Financial institutions are not allowed to invest or lend out 100% of the money they have on deposit. No, there are particular rules that require different types of deposits be held in reserve and just sit there.
Reg D is firmly a Safety and Soundness regulation.
Even though it is not a consumer protection regulation, there are components that require the understanding and attention of a compliance officer. There are eligibility requirements and both mandatory and optional withdrawal limitations.
* Please note that the recording links will be delivered to you via a downloadable PDF in your confirmation e-mail. The PowerPoint that corresponds with the recording will be automatically delivered upon purchasing via email from the website.
