Community banks · Compliance
Reg DD / Truth in Savings website disclosure check
What such a check covers on your deposit pages, and which rule applies to whom.
A Reg DD website disclosure check reads your public deposit pages against the advertising rules in Regulation DD — 12 CFR part 1030, “Truth in Savings”, and in particular section 1030.8. It records every rate of return your pages show and how it is labelled, since paragraph (b) requires a stated rate to be given as an annual percentage yield, then checks what accompanies it: variable-rate information, minimum balances, the effect of fees, time-account terms and bonus conditions. Each observation names the paragraph it relates to, and none of them concludes that your institution has violated the rule.
One distinction matters before you start: 12 CFR 1030.1 provides that Regulation DD applies to depository institutions exceptfor credit unions. A credit union should be read against the NCUA’s parallel rule, 12 CFR part 707, whose advertising section is 707.8.
Educational information, not legal advice.
What the check looks at
The rule text below was read from the official source, and each item names the paragraph it comes from.
Misleading or inaccurate advertisements
Paragraph (a) of 12 CFR 1030.8 addresses advertisements that misrepresent the deposit contract, and the conditions on describing an account as "free". A check reads your deposit pages for claims of that shape.
12 CFR 1030.8(a)
Rates stated as an annual percentage yield
Paragraph (b) requires that where "an advertisement states a rate of return, it shall state the rate as an ‘annual percentage yield’". The abbreviation APY may be used where the full term appears at least once. A check records every rate shown on your public pages and how it is labelled.
12 CFR 1030.8(b)
When additional disclosures are required
Paragraph (c) addresses disclosure of variable-rate information, time periods, minimum balances, opening deposits, the effect of fees, and for time accounts terms such as early withdrawal penalties. Paragraph (d) sets out what an advertisement stating a bonus must disclose.
12 CFR 1030.8(c)-(d)
What the exemptions do and do not cover
Paragraph (e) provides exceptions for certain media, including broadcast, outdoor signage and telephone response systems, with modified requirements for indoor signs. A check notes where a page relies on an exemption that does not apply to a web page.
12 CFR 1030.8(e)
Banks and credit unions are under different rules here
Regulation DD, 12 CFR part 1030, is issued by the Bureau of Consumer Financial Protection and applies to depository institutions except for credit unions. The National Credit Union Administration issues the parallel Truth in Savings rule for credit unions at 12 CFR part 707, with its advertising section at 707.8. The two are closely parallel in substance, and a check names whichever one applies to you rather than treating the pair as one rule.
Educational information, not legal advice.
Questions banks ask about Reg DD on a website
- What is a Reg DD website disclosure check?
- It is a read of your public deposit pages against the advertising rules in Regulation DD, at 12 CFR 1030.8. It records every rate of return shown, how it is labelled, and what accompanies it — variable-rate information, minimum balances, the effect of fees, time-account terms and bonus conditions — and names the paragraph of the rule each observation relates to. It reaches no conclusion about whether your institution has violated the rule.
- What is Regulation DD?
- Regulation DD is 12 CFR part 1030, "Truth in Savings", issued by the Bureau of Consumer Financial Protection to implement the Truth in Savings Act of 1991. The Act is Title 12, Chapter 44 of the U.S. Code, beginning at 12 U.S.C. 4301. Its stated purpose is to enable consumers to make informed decisions about accounts at depository institutions by requiring disclosures that allow meaningful comparison.
- Does Regulation DD apply to credit unions?
- No — and this is worth stating plainly, because it is commonly blurred. 12 CFR 1030.1 provides that Regulation DD applies to depository institutions except for credit unions. Credit unions are covered by the National Credit Union Administration’s parallel rule, 12 CFR part 707, also called Truth in Savings, whose advertising section is 707.8. The substance is closely parallel, but a credit union should be read against part 707 and not part 1030.
- Do we have to write out "annual percentage yield" every time?
- Paragraph (b) of 12 CFR 1030.8 requires a stated rate of return to be stated as an annual percentage yield, and the abbreviation APY may be used where the full term appears at least once. A check records where a rate appears and whether the full term appears with it.
- Does the advertising rule reach pages we did not write?
- The coverage of the advertising rules extends beyond the institution itself: 12 CFR 1030.1 notes they apply to anyone who advertises such accounts, including deposit brokers. In practice that means a rate published on your behalf elsewhere is worth looking at too.
- Will you tell us whether we are in violation?
- No. We describe what is on the page and the paragraph of the rule that speaks to it, and hand it to your compliance counsel. Whether a particular disclosure satisfies the rule is a judgement for them.
In short: a Reg DD check reads the rates and deposit claims on your public pages against 12 CFR 1030.8, names the paragraph behind each observation, and leaves the judgement to your counsel — and if you are a credit union, the rule to read yourself against is 12 CFR part 707.
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