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One of the most common areas of confusion and errors, as it relates to the deposit side of the bank, is the inconsistent use of fee and term language.
Truth in Savings has this thing that says you’ve got a Truth in Savings Act disclosure (TISA Disclosure) that describes your product, and your fees, and how things work. Then that language has to match up with the periodic statement. If you say overdraft on the TISA Disclosure you need to say overdraft on the Periodic Statement. Be consistent in the terminology, I know it’s a minor thing but it’s something that’s a very ticky-tacky thing that examiners very easily pick up on along the way.
What about other spaces, like a website, and marketing, and brochures, and things like that? Well, that space isn’t governed by Truth in Savings. It’s going to be governed more so by the Unfair Deceptive or Abusive Acts or Practices (UDAAP). That’s a very subjective area, so it comes down to how I perceive it versus how you perceived it if we’re talking about auditors and examiners. You win some and you lose some when it comes down to that.
We want to try to mitigate UDAAP Risks, so it’d be best if you just make sure that whatever we say on the TISA Disclosure matches up with whatever we say on the Periodic Statement. Those other spaces that have to do with marketing, and brochures, and the website, we do the same things there as well.
This is just one element of compliance in the deposit operations side of the bank. We’re going to be covering this in several other deposit operations, compliance requirements, as well as some of the hot-button issues currently affecting that area of the industry in our two-hour webinar special on August 28th.
We’ll be taking some questions that you can pre-submit. We’ll also be taking questions live during the presentation. All of the compliance is going to be provided back to you in a plain English format.