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Market Briefing · The Hill Report
An Advertised Savings Yield Is Computed by One Federal Formula
A 1991 law fixes how a savings rate must be stated and what must accompany it,
while a separate set of rules decides whether money parked through an app is
insured at the bank behind it. Connor Hill · InsightfulWord · October 11
Key points
Under the Truth in Savings Act of 1991, any advertisement that states a rate
of return on a bank deposit must state it as anannual percentage yield,
calculated by a single formula over a365-day period.
A disclosed yield is considered accurate if it is within 0.05 of a percentage
point; a variable rate may change without advance notice, but the advertisement
must say the rate may change.
Deposit insurance covers $250,000 per depositor, per insured bank, per
ownership category, and can pass through an app to each customer when the
records identify who owns the money.
The Federal Deposit Insurance Corporation's proposed recordkeeping rule for
custodial accounts, issued after the2024 Synapse collapse, is still listed with
a final-rule date "to be determined."
The advertised yield is usually the first number a saver sees, and it is not a
marketing choice. Federal rules dictate how it is calculated, how it is rounded
and what has to be printed next to it.
A second set of rules decides what happens to the balance itself. When an app
holds customer money at one or more partner banks, deposit insurance can reach
each customer, but only if the records meet conditions the insurer has spelled
out.
On the tape
Oct 9The Federal Deposit Insurance Corporation published a proposed rule on
extensions of credit to bank insiders; a check of its Federal Register
documents from Oct 3 to Oct 10 found no final rule on custodial deposit
accounts.Why it matters: the recordkeeping proposal written after the Synapse
collapse remains open.
Oct 8A Financial Times analysis, as reported by two other outlets, estimated
that AI agents shifting idle balances to higher-yielding products could put
about $500 billion of U.S. bank equity value at risk.Why it matters: the easier
deposits are to move, the more weight falls on comparable, standardized yield
disclosures.
Oct 7Minutes of the Federal Reserve's Sept 15–16 meeting showed officials
raised the federal funds target range a quarter point to 3.75% to 4.00%, with
most expecting another increase by year-end.Why it matters: rates on
variable-rate savings accounts can follow policy moves, and federal rules
require no advance notice when they do.
Oct 6Chairman Travis Hill of the Federal Deposit Insurance Corporation
discussed the agency's pending stablecoin proposals, including their treatment
of pass-through insurance at a St. Louis Fed conference, American Banker
reported.Why it matters: pass-through insurance is the mechanism that lets an
app customer's money be insured as that customer's own deposit.
Sep 25Regulators closed Nano Banc of Irvine, California, which held $686
million in deposits; Sunwest Bank agreed to assume substantially all of them.
Why it matters: it was reported as the sixth bank failure of 2026, the kind of
event deposit insurance is built to cover.
How the Annual Percentage Yield Is Computed
The Truth in Savings Act was enacted on December 19, 1991, as part of a larger
banking law. Its stated aim is uniform disclosure of interest and fees,
allowing "meaningful comparison between the competing claims" of different
banks.
The rules sit in Regulation DD, administered by the Consumer Financial
Protection Bureau. The regulation defines the annual percentage yield as "a
percentage rate reflecting the total amount of interest paid on an account,"
based on the interest rate and the frequency of compounding over 365 days. The
interest rate, by contrast, is the annual rate "which does not reflect
compounding."
The formula appears in an appendix to the regulation. The yield equals 100
times the result of one plus interest divided by principal, raised to the power
of 365 divided by the days in the term, minus one. For an account with no
stated term, the term is treated as 365 days, and the formula collapses to
interest divided by principal. The regulation's own worked example pays $61.68
on a $1,000 deposit over a year, an annual percentage yield of 6.17%.
The yield is rounded to the nearest hundredth of a percentage point and is
considered accurate if it is not more than one-twentieth of a point above or
below the correct figure.
By the numbers
1991Year the Truth in Savings Act was enacted, on December 19
365Days over which every annual percentage yield is computed
0.05Percentage-point tolerance within which a disclosed yield is accurate
$10Value above which a gift for opening or keeping an account is a regulated
bonus
30Calendar days of notice for adverse changes, other than variable-rate moves
$250,000Standard insurance per depositor, per insured bank, per ownership
category
What Must Travel With an Advertised Rate
The advertising section reaches beyond banks. Regulation DD applies to
depository institutions other than credit unions, which follow a parallel rule,
but its advertising provisions apply to "any person who advertises an account
offered by a depository institution."
If an advertisement states a rate of return, it must be stated as an "annual
percentage yield," using that term; the abbreviation is permitted once the full
term appears. The plain interest rate may appear alongside it, but "not more
conspicuously than" the yield. An account with possible maintenance fees may
not be called "free."
Once a yield is stated, several items must appear clearly and conspicuously,
as applicable: a statement that the rate may change after the account is
opened, for variable-rate accounts; the period during which the yield will be
offered; the minimum balance needed to earn it; any higher minimum deposit to
open the account; and a statement that fees could reduce earnings. A bonus,
defined as consideration worth more than $10, brings its own list, including
the time and balance requirements and when the bonus will be paid.
Variable rates carry a further set of account-opening disclosures: the fact
that the rate and yield may change, how the rate is determined, how often it
may change and any limit on the change. Most adverse changes to account terms
require 30 calendar days' notice, but the regulation exempts "changes in the
interest rate and corresponding changes in the annual percentage yield in
variable-rate accounts."
💵 Yield Signal0.05
The tolerance, in percentage points, within which a disclosed annual
percentage yield counts as accurate under Regulation DD. Yields are rounded to
two decimal places and computed over 365 days by one formula, which is why the
same figure from two different institutions describes the same arithmetic, even
when the minimum balances, offer periods and variable-rate terms printed beside
it differ.
How Insurance Passes Through an App to a Bank
The standard insurance amount is $250,000 per depositor, per insured bank, for
each account ownership category, and accounts at different insured banks each
receive their own limit. A program that spreads balances across several banks
therefore relies on each bank's separate limit.
When a company deposits customer money in its own name, coverage can still
"pass through" to each customer. The insurer's guidance for bankers lists three
conditions: the funds must in fact be owned by the customers rather than the
company; the bank's account records must show the agency nature of the account;
and records kept by the bank, the company or another party in the usual course
of business must identify each owner and that owner's interest. If the
conditions fail, the deposit is insured to the named account holder, which
"could result in uninsured deposits."
Remarks posted on the insurer's website in March 2026 described pass-through
as insuring a deposit "as if deposited directly by the end-customer," instead
of as one corporate account "eligible for only $250,000 of insurance." A 2022
advisory drew the outer line: the agency "only pays deposit insurance after an
insured bank fails," and coverage does not protect a nonbank's customers
against that company's "default, insolvency, or bankruptcy."
Synapse, a middleware firm between apps and banks, filed for bankruptcy in
April 2024; hearings found a gap of $60 million to $90 million between its
records and its partner banks' records.
The insurer's response, approved in September 2024, would require banks
holding custodial accounts with transactional features to keep records of each
beneficial owner, balance and ownership category, and to reconcile them at
least daily. Its federal agenda lists the final rule as "to be determined."
Separately, a January 2026 rule narrowed where banks must show the official
digital insurance sign, with compliance due April 1, 2027, and left the ban on
misrepresenting insured status substantively unchanged.
Where the rules sit
Consumer Financial Protection Bureau, Regulation DDYield formula, rounding,
advertising disclosuresAccurate within 0.05 point
Federal Deposit Insurance Corporation, deposit insurance rulesThree conditions
for pass-through coverage$250,000 per depositor, per bank, per category
Federal Deposit Insurance Corporation, custodial account proposalOwner
records, daily reconciliationProposed Oct 2, 2024; final date undetermined
Federal Deposit Insurance Corporation, official sign ruleDigital sign on
homepage, login and account openingCompliance April 1, 2027
One question for the desk
When a savings rate appears in an app, does the screen show who holds the
money and whether the rate is variable, or does that take a second click?
Hit reply — one line is enough.
Worth stating plainly
Federal law requires that any advertised return on a bank deposit be stated as
an annual percentage yield, computed by one formula and accompanied by terms
such as whether the rate is variable and how long it is offered. Deposit
insurance reaches app customers through pass-through coverage when records
identify each owner, and it is paid out when an insured bank fails.
The short checklist
1.Look for the term "annual percentage yield" and read the disclosures printed
beside it.
2.Check whether the rate is variable, how it is set and how long an advertised
yield is offered.
3.Note any minimum balance, opening deposit or fee that could reduce earnings.
4.Identify the insured bank or banks that actually hold the balance.
5.Confirm that the account terms describe pass-through coverage and who keeps
the ownership records.
6.Keep totals per bank and ownership category within the $250,000 standard
limit.
Replies to this briefing reach a person, not a queue.
Connor Hill reads every reply.
Sources checked Verified October 10, 2026 Truth in Savings Act, 12 U.S.C. 4301
et seq., Public Law 102-242, December 19, 1991, and Regulation DD, 12 CFR Part
1030, sections 1030.1 to 1030.8 and Appendix A, current as of October 7, 2026
Federal Deposit Insurance Corporation, deposit insurance guide for bankers on
pass-through coverage, Deposits at a Glance, and the July 2022 advisory on
nonbank misrepresentation Federal Deposit Insurance Corporation, proposed rule
on recordkeeping for custodial accounts, September 2024, and its Unified Agenda
entry; Federal Register listings for October 3 to 10, 2026 Federal Register,
final rule amending 12 CFR Part 328 on official signs, January 29, 2026, and
FDIC remarks to the ABA Washington Summit, March 2026 American Banker on
Synapse refunds, December 22, 2025, and on remarks by the FDIC chairman,
October 6, 2026; ABA Banking Journal and Banking Dive on Nano Banc, September
26, 2026 Federal Reserve statement of September 16, 2026, and PNC Economics
summary of the minutes, October 7, 2026; iProUP and Behind Fintech on the
Financial Times deposit analysis, October 8, 2026 Connor Hill writes The Hill
Report for InsightfulWord, a daily briefing on the machinery behind the numbers.
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