We're buying some accounts, and changing some of the features when we do. One of the changes is to the tiers on interest bearing accounts. We have three tiers, the accounts currently have five. The first three current tiers are all within our first tier.

So, what do you think? Is it adverse? Would we have to evaluate the interest being paid on each tier in both institutions, or is it going to matter?

DD says,

"(1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under section 230.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer..."

It's bound to be adverse when you go from 5 to 3, so a notice would be required.

I agree with T. The result is almost certain to be adverse.

However, even if it isn't, I still think you should disclose. This is likely to be your new customers' first impression of your bank. What sort of image do you want to project?