I must be totally missing the point of the regulation. I thought that if you lower a rate for a savings account customer, you have to notify them 30 days before the effective date of the new rate. Is there some exception to this? Our general counsel says, it's OK just to lower the savings rate because our account agreement says we can change the rate whenever the banks requires.

If you have provided the customer with the required variable rate disclosures, your counsel is correct. The rate that you pay on any given day is at the banks discretion and the customer does not have to be notified.

That is exactly how we did it. §230.4(b)(1)(ii)(B) (and in the OSC). But that has to be what you agreed to already.