One requirement of the Truth in Savings Act is that institutions use consistent fee terminology. The Commentary to 12 CFR 1030.3(a) #2 states institutions must use consistent terminology to describe terms or features required to be disclosed. For example, if an institution describes a monthly fee (regardless of account activity) as a “monthly service fee” in account-opening disclosures, the periodic statement and change-in-term notices must use the same terminology so that consumers can readily identify the fee. While this requirement pertains specifically to §1030.4 (Account disclosures), §1030.5 (Subsequent disclosures) and §1030.6 (Periodic statement disclosures), we often recommend that institutions apply this same consistent terminology standard wherever it might come into play. One example would an institution’s website. Not only does this help ensure clarity and understanding for consumers but it can help avoid any potential UDAAP concerns as well.
Kevin explains more in the video.
Published
2025/03/26
