Truth In Savings Act (Regulation DD)
Summary of Law and Regulations
The Truth in Savings Act (TIS) and regulation DD (12CFR230) requires depository institutions to provide consumers with disclosures regarding the specific account terms, conditions, and fees on certain deposit accounts.
Disclosures must be provided upon request, as well as prior to opening an account. In addition, certain information must be included on periodic statements, and a change in term's notice must be provided at least 30 days prior to making a change that will adversely affect the consumer.
The act and regulation also require the use of the daily balance or average daily balance method to determine the balance on which interest is calculated and establishes specific rules regarding advertising.
Internal Controls/Procedures
Account Officer provides Regulation DD disclosures to the consumer prior to opening a deposit account or upon receiving a request for such information. In addition, when responding to telephone inquires, representatives state the "Annual Percentage Yield" for the requested product and, if requested, provide account disclosures to the inquirer. Disclosures are prepared using the JHA software, which calculates the APYs, and provides appropriate disclosure of terms and fees for that particular account.
If interest accrual methods are changed for any deposit product, Regulation DD disclosures are revised accordingly. In addition, the Compliance Officer maintains records of compliant resolution approved by the Chief Financial Officer and includes resolution procedures in employee training sessions.
