One violation that our Review Team finds pretty consistently is the Truth in Savings Act (Regulation DD) requirement to use consistent 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. This is all about clarity and doing what you say and saying what you do. Unfortunately, this is also an area where you can things are all good to go and then somewhere along the way after a system update, things don’t match up anymore. And while the regulation doesn’t specifically require consistent terminology with your website, for example, it’s a good idea to make sure things are the same there too because you never know when an examiner might start thinking UDAAP.
Kevin explains more in the video.
Published
2024/12/03
