We are looking at rolling out an Index Powered CD tied to the performance of the S&P 500. The return of principal is quaranteed by the bank and protected by FDIC insurance. Has anyone advertised this type of product before and how did you satisfy Reg. DD 230.8 with regards to advertising a rate since there is no APY? Also, interest will not begin to accrue until the "issue date" which could be a several days after the deposit is received (due to the offering period). Any thoughts on this practice? Thank you.

There is no guaranteed floor rate on the CD? Most of the indexed CD's start with a floor rate, in which case you disclose the APY for the floor rate and it is just a variable rate CD and you disclosure how the future rate will be determined.

IMHO - If the CD had no floor rate, you are going to have a hard time selling the product in the typical retail market.