Truth in Savings Act Change in Terms

The Truth in Savings Act (Regulation DD) is all about getting information in the hands of consumers so they can make informed decisions about rates, fees and account terms. It outlines certain disclosures that must be provided when a consumer inquires about an account, when they open an account, on their periodic statements, when you advertise an account, etc. Institutions need to be aware that if certain information changes after it’s been provided, there are certain instances where advance notice of the change is required. Specifically, 12 CFR 1030.5 states:

A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under §1030.4(b) of this part (aka the initial TISA disclosure provided at account opening) if the change may reduce the annual percentage yield or adversely affect the consumer. The notice shall include the effective date of the change. The notice shall be mailed or delivered at least 30 calendar days before the effective date of the change.

As with anything in compliance, there are also some exclusions.

Kevin explains more in the video.


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Video Highlights:

  • Certain changes in account terms must be disclosed 30 days prior to the effective date of the change.
  • If a new TISA disclosure is provided, the changes should be highlighted as to what specifically changed.
  • Advance notice is not required for interest rate/APY changes on a variable rate account, when changing fees related to check printing, or changes for time accounts with maturities of one month or less.

Published
2024/02/06

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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