We are putting together a new money market account with the following features:

Initial premium rate for 45 days
It will be disclosed as a variable rate
After the 45 days it will be a tiered rate depending on the balance maitained.

Our retail VP has insisted that the bank can refer to a rate sheet regarding the various tiers. I beleive we would have to initally state the balances and appropriate apy in the disclosure instead of referring to a rate sheet. After that we would be ok since it will be disclosed as a variable rate product.
Please let me know your thoughts. Thanks