Questions and Answers

No. Regulation Z says that if you require a deposit as a condition for the credit, you must disclose the fact that the effect of the required disclosure is not reflected in the APR. A footnote adds that "required deposit need not include ...a deposit that earns not less than 5 percent per year..." That means that a deposit earning exactly 5 percent (or higher) need not be a required deposit. The "need not" phrase suggests that you could treat the deposit as a required deposit and make the disclosure if you wished. But you are not required to make the disclosure.