Questions and Answers
Does truth in savings require that we use a special calculation method for determining the minimum balance before we impose a fee?
No. Truth in Savings/Regulation DD requires disclosure of any “minimum balance required to...avoid the imposition of a fee” and of “how the balance is determined for” this purpose. Reg. DD also requires disclosure of the “amount of any fee that may be imposed in connection with the account (or an explanation of how the fee will be determined) and the conditions under which the fee may be imposed”. However, Reg. DD does not prescribe the method of calculation that must be used to determine the fee.
(Posted: 09/10/2007)