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FED ER A L R ESER VE BANK
O F N EW YORK

A p ril 9, 1979

REGULATION Q
Revised G uidelines for Issuing and Advertising “M oney Market Certificates”

To All Member Banks in the Second Federal Reserve District:

In view of the amendment, effective March 15, 1979, to Regulation Q that prohibits the
compounding of interest on “money market certificates,” the Board of Governors of the Federal
Reserve System has revised its guidelines for the offering and advertising of such deposits.
The previous guidelines were sent to you on August 16, 1978.
The Board of Governors indicated that the guidelines have been revised—
. . . by eliminating references to compounding formerly contained in the discussions concerning how
the ceiling rate on the certificate is determined and in the guidelines concerning how the rate of interest
may be advertised. In addition, a new guideline three has been added which requires member banks to indi­
cate clearly and conspicuously in all advertisements, announcements or solicitations that Federal regula­
tions prohibit the compounding of interest during the term of the money market certificate. The new guide­
line also provides that an annual effective rate of interest on the certificate based upon a reinvestment at
maturity of principal and interest earned (which rate member banks are permitted to advertise) shall
not include any additional return that a depositor may earn by reinvesting his or her interest during the
term of the certificate. The appendix . . . also has been revised to eliminate references to compounding.

Enclosed is a copy of a statement containing the text of the new guidelines. You may wish
to keep it with Regulation Q in your Regulation binder. Questions may be directed to our
Consumer Affairs and Bank Regulations Department (Tel. No. 212-791-5919).




P aul

A.

V olcker,

President.

Board of Governors o f the Federal R eserve System
IN TER EST ON DEPO SITS

STATEMENT REGARDING NEW 26-WEEK TIM E DEPOSITS
Effective June 1, 1978, the Board amended
section 217.7 of Regulation Q to authorize
member banks to pay interest on nonnegotiable
time deposits of $ 10,000 or more with maturi­
ties of exactly 26 weeks at a maximum rate
equal to the discount rate on the most recently
issued six-month United States Treasury bills
(auction average). Effective March 15, 1979,
the Board amended that section of Regulation
Q to prohibit compounding on these money
market certificates. Since the Board’s actions,
questions have been received concerning the of­
fering of the 26-week instrument by member
banks. This letter responds to the most fre­
quently raised questions and provides general
guidelines for advertising the new 26-week time
deposit.

How is the ceiling rate on the certificate deter­
mined?
The ceiling rate for new 26-week time de­
posits equals the discount rate (auction average)
for United States Treasury bills with maturities
of six months issued on or immediately prior to
the date of deposit. The ceiling rate is not estab­
lished with reference to the coupon-equivalent
or effective yield on Treasury bills. Should a
member bank desire to round off the ceiling
rate, such rate may only be rounded down. For
example, if the discount rate on Treasury bills
is 6.4638 percent, a member bank may round
this ceiling rate to 6.463 percent, 6.46 percent
or 6.4 percent. Daily interest may be computed
on a 360, 365, or, in a leap year, 366-day basis
in accordance with the provisions of § 217.3(e)
of Regulation Q. However, member banks are
prohibited from compounding interest during
the term of the deposit on certificates issued or
renewed on or after March 15, 1979.
When does the ceiling rate on new deposits
change?
United States Treasury bills maturing in six
months (26 weeks) are auctioned weekly by the
Treasury Department, normally on Monday,
and normally are issued the following Thurs­
day. Beginning on the date the Treasury bills
are issued, member banks may pay interest on
new time deposits with 26-week maturities at a
ceiling rate not to exceed the discount rate (auc­
tion average) established for Treasury bills and

may continue to pay such rate on new 26-week
time deposits until the next issue of six-month
Treasury bills. At that time the average dis­
count rate on the new issue of six-month Trea­
sury bills becomes the ceiling rate for new time
deposits. For example, the ceiling rate payable
on Thursday, August 3, would be fixed at the
discount rate (auction average) established on
Monday, July 31. That ceiling rate would re­
main in effect for new time deposits through
Wednesday, August 9. On Thursday, August
10, the ceiling rate on new time deposits would
change to correspond to the discount rate
(average auction) established on Monday, Au­
gust 7.

Must the maturity of the certificate be 26 weeks
exactly or may it be six calendar months?
The maturity of the certificate must be ex­
actly 26 weeks (182 days) and not six calendar
months. However, where the certificate would
mature on a legal holiday, it may be issued with
an original maturity in excess of 26 weeks (182
days) so that it would mature on the next
succeeding business day. This position is con­
sistent with the similar treatment accorded sixmonth Treasury bills that would otherwise ma­
ture on a holiday and is consistent with If 3349
of the Board’s Published Interpretations (12
CFR 217.134) which generally provides that a
member bank may pay interest on a certificate
that matures on a legal holiday until the next
succeeding business day. However, upon re­
newal, such certificate must be issued for exactly
26 weeks.
How is the early withdrawal penalty rule applied
to the certificate?
The 26-week certificate is treated like other
time deposits for purposes of the Regulation Q
early withdrawal penalty. In accordance with
§ 2l7.4(d) of Regulation Q (12 CFR
217.4(d)), if the deposit or any portion is paid
before maturity, a member bank may pay in­
terest on the amount withdrawn at a rate not to
exceed that prescribed for a savings deposit
(currently five percent) and, in addition, a for­
feiture of three months’ interest at such rate is
required. However, if the amount withdrawn
has been on deposit for three months or less, the
minimum penalty consists of the forfeiture of
all interest for the period of time the funds were

[ Enc. AT 8552 ]




PRINTED IN NEW YORK

on deposit. As is the case with other time de­
posits, as an alternative to payment before ma­
turity, member banks are permitted to lend on
the collateral of such time deposit so long as
the rate charged on the loan is at least one per­
cent higher than the rate paid on the deposit
pledged.
May the certificate be issued in denominations
of $10,000 onlyt
The $10,000 requirement is a minimum de­
nomination requirement and a member bank
may issue the certificate in any denomination
of $10,000 or more. As with other time deposits,
banks may offer this certificate in discount form
where the face amount of the certificate is
received by the depositor at maturity, so long
as the bank initially receives at least $ 10,000
from the depositor and the rate paid on the net
amount deposited does not exceed the applicable
six-month Treasury bill discount rate. See
If 3365 of the Board’s Published Interpretations
(12 CFR 217.149).

How may the rate of interest be advertisedf
A number of questions have been received
regarding the appropriate methods of advertis­
ing the rate of interest that may be paid on the
new 26-week certificate. In particular, these
questions concern advertisements that compare
a rate or yield on the certificate with a rate or
yield on six-month Treasury bills.
A member bank’s advertising that the rate of
interest paid on its 26-week time deposits
“equals" the Treasury bill rate may confuse
depositors since Treasury bills are sold at a
discount and the effective yield on Treasury bills
is higher than the discount rate. Accordingly,
any general comparison to Treasury bill rates
that conveys the impression that the rate paid
by the bank equals the coupon-equivalent or
effective yield on Treasury bills would be in­
appropriate.
The Board has stated that member banks
may advertise an annual effective rate of inter­
est for money market time deposits based upon
a reinvestment at maturity of principal and in­
terest earned. However, a bank’s advertising an
annual effective rate based on reinvestment of
principal and interest for the entire year may
imply an agreement to pay that rate for the en­
tire year. In fact, such rate may not be available
since the certificate matures in 26 weeks qnd
can only be renewed at a rate no more than
the ceilng rate in effect at the time of renewal.
In view of these considerations, the follow­
ing advertising guidelines are provided. These




guidelines amplify the specific disclosure and
advertising requirements contained in Regula­
tion Q that are applicable generally to all de­
posits. See §217.6 of Regulation Q (12 CFR
217.6). These guidelines are applicable to every
member bank advertisement, announcement or
solicitation relating to the 26-week certificate.
Guidelines

1. Any advertisement, announcement or so­
licitation that states an annual effective yield
based on reinvestment of principal and interest
at maturity must contain a clear and conspicu­
ous statement that the rate stated is an annual
rate and that this rate is subject to change upon
renewal. Such a statement could be expressed
in the following manner:
This is an annual rate and is subject to change
at renewal.
It is believed appropriate to impose this re­
quirement on advertisements, announcements
and solicitations relating to the 26-week certifi­
cate, but not on other time deposits with original
maturities of less than one year, because the
ceiling rates applicable to such other time de­
posits change infrequently and such deposits
are typically renewed by the bank at the same
rate.
2. In any advertisement, announcement or
solicitation, the following guidelines also apply:
(a) If a member bank’s advertisement,
announcement or solicitation makes any ref­
erence to U.S. Treasury bills, it must promi­
nently disclose that the rate of interest paid
on Treasury bills is the discount rate. Such
advertisement, announcement or solicitation
must also contain a statement that the effec­
tive yield on Treasury bills is higher than the
discount rate.
(b) If a member bank’s advertisement, an­
nouncement or solicitation makes any refer­
ence to U.S. Treasury bills and expresses
any specific rate (bank’s rate or Treasury’s
rate), it must prominently disclose the cou­
pon-equivalent or effective yield on U.S.
Treasury bills and the effective yield on its
certificate computed on a comparable basis.
If such disclosures are made, the required
statement in (a) above that the effective
yield on Treasury bills is higher than the
discount rate need not appear.
(1) If a member bank advertises an effec­
tive yield that is equal to (or lower than)
the discount rate (the ceiling rate on the
certificate) and makes any reference to
Treasury bills, the bank’s yield must be
compared with the coupon-equivalent or

effective yield on a six-month Treasury bill.
(2) If a member bank advertises an effec­
tive yield based on reinvestment at ma­
turity of principal and interest earned and
makes any reference to Treasury bills, the
bank’s yield must be compared with an
effective yield on six-month Treasury bills
that is adjusted to reflect reinvestment of
proceeds at maturity. (For your conve­
nience, methods of calculation are provided
in the attached appendix.)
3.
The Board believes it appropriate for all
member bank advertisements, announcements,
and solicitations, including deposit account bro­
chures and other literature concerning money
market time deposits, to indicate clearly and
conspicuously that Federal regulations prohibit
the compounding of interest during the term
of the deposit. In this connection, member banks

may continue to pay interest to depositors in
the usual manner (e.g. monthly, quarterly or
semi-annually) in accordance with customary
banking practice or the bank’s current interest
payment practice. Such interest may be paid to
the depositor or credited to an account main­
tained by the depositor. The annual effective
rate on money market certificates shall not in­
clude any additional return that a depositor
may earn during the term of the money market
deposit by reinvesting his or her interest.
These guidelines also apply in any advertise­
ment, announcement or solicitation in which a
bank compares the rate it pays on the certificate
with the rates paid on competing instruments
of others. Guidelines 2(a) and 2(b) need not
apply to advertisements, announcements or so­
licitations that contain no reference to Treas­
ury bills or other competing instruments.

A PPE N D IX

This appendix provides information for mem­
ber banks that wish to advertise comparisons
between yields offered on the 26-week certifi­
cate and yields on six-month Treasury bills.
1. As noted in the accompanying letter, if
a member bank advertises an annual effective
yield which does not take into account reinvest­
ment of interest after the 26-week maturity of
the certificate and refers to Treasury bills, it
should compare this rate to the coupon-equiva­
lent yield on Treasury bills. The coupon-equiva­
lent yield on Treasury bills is widely published
and is made available by the Treasury and the
Federal Reserve Banks.
2. If a member bank advertises an annual
effective yield which takes into account rein­
vestment of interest at maturity and refers to
Treasury bills, it should compare its rate to the
Treasury bill coupon-equivalent yield adjusted
to make the yields comparable. For example,
if a member bank advertises such an annual
effective yield arrived at by assuming a 365day year, the appropriate effective yield on
Treasury bills would be calculated as follows:




Treasury Bill Yield =
(1 + CEY ( § ) ) M . i
where CEY is the coupon-equivalent yield for
Treasury bills. For six month Treasury bills
issued on June 1, 1978 (coupon-equivalent
yield of 7.532 percent), the adjusted yield on
Treasury bills would be 7.674 percent:
.07674 = (1 + .07532 ( 1 | ) ) 2 | _ 1
If a member bank advertises an annual effec­
tive yield assuming reinvestment of interest for
a 360-day year, the comparable Treasury bill
yield must also be adjusted to a 360-day basis.
The adjusted effective yield on Treasury bills
would then be calculated as follows:
Treasury Bill Yield =

(1 + C E Y ( f f ) ) f ° - l
Note that no adjustment should be made to the
fraction (182/365), since the coupon-equivalent
yield on Treasury bills is expressed on the
basis of a 365-day year.