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Are banks required to list the interest rate along with the annual percentage yield (APY) paid on a deposit account on the rate sheet provided to consumers at account opening? May the bank use just the APY?

No, if the rate sheet is being used to comply with the account opening disclosures of Regulation DD (Truth in Savings Act), but yes if the bank is using the rate sheet solely for advertising purposes. Interest rate information is required in Regulation DD disclosures but not advertisements.

See the content of account opening disclosures at §1030.4(b)(1)): “An institution must disclose both the ‘annual percentage yield’ and the ‘interest rate’ using those terms.” If the bank is using a rate sheet as a disclosure then the interest rate is required along with the APY.

The answer is different if the bank is using the rate sheet as an advertisement or if the bank disclosed the interest rate elsewhere in the account opening disclosures. For advertisements, the bank need only disclose the APY. The Regulation DD advertising rules at §1030.8 state:

(b) Permissible rates. If an advertisement states a rate of return, it shall state the rate as an “annual percentage yield…” The advertisement shall not state any other rate, except that the “interest rate,” using that term, may be stated in conjunction with, but not more conspicuously than, the annual percentage yield to which it relates.

(July 2019)

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