Under what circumstances must we provide Truth in Savings Act (TISA) disclosures? If someone asks about a thirty-month certificate of deposit (CD), can we provide that person with just the rate sheet and annual percentage yield (APY), or are TISA disclosures required? When does a customer’s inquiry trigger TISA disclosures?

Your bank is not required to provide TISA disclosures when a consumer makes an oral inquiry (by telephone or in person) about the terms of a specific account. However, you are required to provide TISA disclosures when a consumer requests written information about an account — whether by telephone, in person, or by other means. Accordingly, if you are providing a written rate sheet to a consumer, you also should provide TISA disclosures.

If a consumer makes an in-person request for written information, TISA disclosures must be provided at that time. If the consumer is not present in-person when making a request for written information, TISA disclosures must be sent to the consumer within ten business days of the request, either in paper form or, if the consumer agrees, to their email address or on your website. We note that such electronic disclosures may be made without regard to the consumer consent or other provisions of the E-Sign Act.

For resources related to our guidance, please see:

  • Regulation DD, Official Interpretations, Paragraph 4(a)(2)(i), Comment 1 (“A response to an oral inquiry (by telephone or in person) about rates and yields or fees does not trigger the duty to provide account disclosures. But when consumers ask for written information about an account (whether by telephone, in person, or by other means), the institution must provide disclosures unless the account is no longer offered to the public.”)
  • Regulation DD, 12 CFR 1030.4(a)(2)(i) (“A depository institution shall provide account disclosures to a consumer upon request. If a consumer who is not present at the institution makes a request, the institution shall mail or deliver the disclosures within a reasonable time after it receives the request and may provide the disclosures in paper form, or electronically if the consumer agrees.”)
  • Regulation DD, Official Interpretations, Paragraph 4(a)(2)(i), Comment 3 (“Ten business days is a reasonable time for responding to requests for account information that consumers do not make in person, including requests made by electronic means (such as by electronic mail).”)
  • Regulation DD, Official Interpretations, Paragraph 4(a)(2)(i), Comment 4. (“If a consumer who is not present at the institution makes a request for account disclosures, including a request made by telephone, email, or via the institution's Web site, the institution may send the disclosures in paper form or, if the consumer agrees, may provide the disclosures electronically, such as to an email address that the consumer provides for that purpose, or on the institution's Web site, without regard to the consumer consent or other provisions of the E-Sign Act. The regulation does not require an institution to provide, nor a consumer to agree to receive, the disclosures required by §1030.4(a)(2) in electronic form.”)