Hi
Is there anything that sates that when disclosing tiered interest rates that tier 1 has to be the lowest tier? Or is it acceptable to have tier 1 be the highest tier?
Ex:
Tier 1 $50,000 and more = .15%
Tier 2 $25,000 - $49,999 = .10%
Tier 3 $5,000 -$24,999 = .05%
Tier 4 $0 - $4,999 = .01%
TIA

You can label them Aardvark, Bandicoot, Crocodile, Dachshund, and Eft if you want, which is just my smart-aleck response that the tiers need not have any label at all. You just have to show each tier's balance range and the APY that applies to it.

Lol!! Thank you

If an accuont only pays interest above a certain dollar threshhold, would that be considered a tiered account?

For example, if an account only paid interest on balances above $15,000. IMO you would only need to disclose that information, not that tier one = zero interest and tier two = x interest.

Is my thinking correct?

Never mind, looking for a quick answer and didn't research long enough! Thanks BOL for the prior thread "Tiered Rate Accounts"! Don't know how to link it here, but thank you!

Due to the low rate environment, we have a three tier account with the same APY. We are working on a mailing which would pay them a bonus for opening this account. For this item, do we need to disclosure all of the tiers or can we just say the current APY is 0.10%?
Example 1: As of 3/26/15, balances of $20,000 and over earn 0.10% Annual Percentage Yield (APY), balances between $19,999.99 and $1,000 earn 0.10% APY, and balances under $1,000 earned 0.10% APY.
Example 2: As of 3/26/15, tiered balances earned 0.10% Annual Percentage Yield.

I would stick with the current tiers. You could "collapse" the 3 tiers BUT later, if/when rates go back up, you want to break them out again, I think you would have a change in terms that is adverse to the interest to the consumer. So then you would have to give a 30 days notice.

We would disclose all of the tiers when they opened the account. This disclosure would only be on the coupon. Does that matter?

If you include the APY as part of a tiered rate account, you must include all tiers on the advertising piece even all tiers have the same APY. See the Official Interpretations to 1030.8.

1. Tiered-rate accounts. An advertisement for a tiered-rate account that states an annual percentage yield must also state the annual percentage yield for each tier, along with corresponding minimum balance requirements. Any interest rates stated must appear in conjunction with the applicable annual percentage yields for each tier.