TISA states minimum balance requirements - any minimum balance required to (C) obtain the APY disclosed

If we are offering a cd that allows the customer to withdraw up to 50% of the cd, do we use the minimum balance to open the account or 1/2 the minimum balance to open the account for purposes of obtaining the APY disclosed.

My guess is that we would state the amount that was actually required to open the account.

Any advice is appreciated. Thanks!

I also believe you would use the amount required to open the certificate. You don't know if anyone is going to withdraw anything.