Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
We recently discovered an error in the interest calculations for some of our deposit accounts. In most cases, we underpaid interest by just a few cents. Does Regulation DD provide a certain tolerance threshold for such “de minimis” errors? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We recently discovered an error in the interest calculations for some of our deposit accounts. In most cases, we underpaid interest by just a few cents. Does Regulation DD provide a certain tolerance threshold for such “de minimis” errors?

—

by

No, there is no de minimis threshold for interest calculation errors for savings accounts in Regulation DD. The Truth in Savings Act formerly required restitution to customers for errors, but that provision was repealed in 2001.

We do recommend providing restitution to the affected customers, since a failure to pay interest as promised, even to a very minor extent, could be criticized by your examiners as a TISA violation and possibly as an unfair, deceptive or abusive act or practice (UDAAP).