We are thinking about offering an 18 month variable rate IRA CD. We have never offered a variable rate IRA or CD. I have never created a product from scratch and don't know where to begin!! The IRA will accept transfers into it, only from within our bank. Will we need to supply monthly statements? Do we need to send a notice each time the rate changes? Any additional disclosures required? HELP!!

We offered a product like this a long time ago. The initial disclosure for the product stated that it was a variable account. Our product was tied to an index and was changed on a certain schedule so we stated the index and when the rate would be changed. Even if your rate is not tied to an index if you disclose it properly up front you do not need to notify customers everytime the rate changes.

If you PM me your email address I can send you a copy of the disclosure we used for this product.

A monthly statement is not required on the account unless you allow electronic deposits that would fall under Reg. E. We send quarterly statements on all CD's including these.