Re: AER - Halifax don't know either

Watch this space for further developments.

Cluelessness continues, though this seems to be a genuine misunderstanding of the nature of my query. Herewith text of Halifax's letter dated 2nd April received today. E&OE.

--quote Thank you for your letter of March 20th 2004. I was sorry to learn of your concern about the way our Regular Saver Account is advertised.

Due to advertising guidelines set down by the British Banking Association, our advertisements must quote the AER and the contractual rate (gross) for accounts. The AER must have the greatest prominence. Therefore to comply with the Code, the AER of 6.05% for the Regular Saver had to be the rate on our advertising material. Our literature does explain that the AER is a notional rate illustrating what the interest would be if it were compounded each year. We do not compound interest on Regular Saver as the customer can change the amount of the standing order and the date funds hit the account. Therefore the contractual rate on which the customer's interest is calculated is 6.00% gross.

The guidance note issued by the BBA in January 1999, which introduced the requirement to quote AER in every advertisement, were produced to ensure that all adverts included one rate which is capable of comparison across all adverts, regardless of product provider and how interest is calculated or paid. We did take legal advice as, given the choice, we would have preferred to promote the contractual gross rate in the most prominent position. As this could not be done without breaching the code, we have followed the guidelines and used the AER.

I can confirm that the interest is paid on the Regular Saver account once, at the end of the 1 year fixed peiod, immediately before the balance and interest are transferred. I am sorry that your local branch was unable to give a satisfactory response to your question. In the light of feedback and enquiries we have received about this new account, our branches have now been issued with information to help them answer queries such as yours.

I hope that I have clarified the situation for you. I enclose a copy of our leaflet, 'Personal Customer Complaints - Here's what we'll do' which explains your options should you remain dissatisfied. It also confirms our membership of,a nd the ultimate availability of, the Financial Ombudsman Service. If I do not hear from you within 8 weeks, I shall assume you are satisfied with my response, and will close your file.

[Customer Relations Manager - Core Business Team]

--unquote

Reply to
Ronald Raygun
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Here's my reply requesting further clarification:

--quote Thank you for your comprehensive reply of 2nd April to my query of

20th March.

Unfortunately it appears that you have misunderstood the nature of my concern. I am not interested in the fact that the AER has greater prominence in your material than has the gross rate. My problem is that it has a greater numeric value.

The nature of my query is one of technical compliance. If you have a compliance department, perhaps you could seek advice from them. There must be someone in the team responsible for the content of your material, who understands the technical issues and can comment.

Essentially your material alleges three facts:

1) That the contractual rate is 6.00%. 2) That the AER is 6.05%. 3) That interest is paid only once at the end of the year.

What I am saying is that it is impossible for more than two of these facts to be true, and I'm trying to discover which one is false.

I draw your attention to the BBA's Code of Conduct for the Advertising of Interest-Bearing Accounts, which in its AER appendix, available at

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confirms that:

"If an account pays or credits interest once a year, then the AER is equal to the gross rate."

Therefore, since your AER is greater than the gross rate, it follows that interest is paid more frequently than yearly. I look forward to receiving a more technical reply which explains why your experts think the AER in the specific circumstances of this account is not equal to the contractual gross rate.

--unquote

Reply to
Ronald Raygun

Notwithstanding the further letter I wrote to Halifax today, I think I've nevertheless cracked it. I look forward to learning whether Halifax's reply, when it comes, confirms my conclusion.

My thinking now goes along the following lines:

If an account pays interest only once, at the end of one year, at a nominal rate of 6%pa or 0.5%pm, and the conditions are that you place a fixed sum on deposit at the start of the year and it stays there all year and you make no withdrawals or further deposits, then clearly the AER and gross rate will both equal exactly 6%.

If an account pays interest only once, at the end of *one month*, at a nominal rate of 0.5%pm, and the conditions are similar to above, that the deposit remain there undiminished and unaugmented for the duration of the period (in this case one month), then we really have an interest application *frequency* which is monthly, even though the interest application only actually happens once. The AER then must be 6.1678%.

If you view the actual Halifax Regular Saver account, for which the conditions are that you deposit the same amount regularly each month, as 12 separate accounts, one lasting for 12 months, one for

11, one for 10, etc, and one for 1, then the AERs of each will take various values between 6.00 and 6.17%, reflecting the fact that the "frequency of compounding" for each will vary beteen "every N months" where N takes all values between 1 and 12, and so the effective composite AER must lie between those values. Obviously it won't be the simple arithmetic mean, but a first crude approximation by weighting the 6.0000 by 12, the 6.1678 by 1, and the inbetween ones by factors 2 to 11, gives me the result 6.0550%, which is a close call between an official 6.05% result and 6.06%. In fact, working to more decimal places, the crude weighting gives an answer which would officially have to be 6.06%, namely 6.05500472%.

When I get a moment I'll apply the full gory formula given in

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the one with those nasty-looking big sigmas and big pi, but rebased to monthly instead of annual periods, and then reverted to annual. It may well give an answer a hair's breadth under 6.055% which would justify the quoted 6.05%.

Reply to
Ronald Raygun

AER's are always rounded down to 2 d.p. (like APR's used to be rounded down to 1 d.p. many moons ago)

Reply to
Pog Mo Thoin

In message , Ronald Raygun writes

I think you've cracked it there RT, BUT it just goes to show how AER (like APR) can actually mislead us.

Ive had a quick look again through the aer link you posted but the overriding rule seems to be this 'once a year' thing, which (unlike APR) doesn't take account of mid-year application of interest.

I await the next instalment......................

Reply to
john boyle

Done properly: Assume you invest £100pm. Using contractual 6% this means at the end of the year you will have capital of £1200 plus interest of £100 x 0.005 x (12+11+..+1 = 78). Total = £1239 (in theory exactly, assuming payments are made at intervals of exactly one month; in practice there is no such thing as an exact month, as deposits are made on a granularity of days, and interest is calculated on a daily basis too, so the answer is approximate).

The AER will be that rate which makes the sum (i = 1 to 12) of £100 x f^(i/12) equal to £1239, where f = 1+AER/100. Indepenent of amount invested, we must have the sum (i = 1 to 12) f^(i/12) equal to 12.39. Turns out f is 1.060543683154336 or so, and hence the rounding *down* from 6.054...% to 6.05% is justified.

Not true. The BBA worked examples show cases where they round up and where they round down. So they evidently round to nearest.

Reply to
Ronald Raygun

I stand corrected!

Reply to
Pog Mo Thoin

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