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#1558895 - 06/01/11 01:56 PM Zero Interest
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
On our rate sheets, do we need to disclose the tiers which do not pay interest?
Tier APY
$0 - $999 0.00%
$1,000 - $2,499 0.10%
$2,500 - $9,999 0.15%
$10,000 - $74,999 0.20%
$75,000 & over 0.25%

If we change tier 2 to no interest, can we remove tier 1 and 2 from our rate sheet? Do we need to give our customers notice?
Last edited by ksm; 06/01/11 02:01 PM.
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#1558965 - 06/01/11 03:20 PM Re: Zero Interest ksm
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You can reduce the rate paid on a given tier to zero without requiring notice to your customers. But if that change will become permanent, it will be an adverse change for your customers, and you'll need to notify them of the change at least 30 days prior to making the change.
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#1559055 - 06/01/11 04:23 PM Re: Zero Interest John Burnett
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
So if we have never paid interest for that tier, we can remove that tier from the rate sheet.

If we decide to lower the APY to zero on the $1,000 to $2,500 tier until rates increase, we do not need to notify the customers. Should we leave this tier on the rate sheet with zero?

If we decide we will never pay interest on the $1,000 to $2,500 tier, we should notify the customer and can remove from the rate sheet.

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#1559060 - 06/01/11 04:26 PM Re: Zero Interest ksm
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 82,149
Galveston, TX
You can put what ever you want on your internal rate sheet. However, if you change the tiers that were originally disclosed to the customer, as John said that would require a change in terms.
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#1559158 - 06/01/11 05:48 PM Re: Zero Interest rlcarey
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
Our deposit rate sheets have all the needed disclosures so they may be handed out to customers.

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#1559172 - 06/01/11 06:04 PM Re: Zero Interest ksm
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 82,149
Galveston, TX
Then I would recommend that you keep all the current tiers listed with a 0% APY, unless you change the terms of the accounts.
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#1559620 - 06/02/11 03:26 PM Re: Zero Interest rlcarey
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
So when the money market account was opened, we disclosed interest will not be paid when the balance is less than $1,000, but we still need to show a tier for less than $1,000 with an APY of 0%?

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#1559629 - 06/02/11 03:36 PM Re: Zero Interest ksm
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 82,149
Galveston, TX
If that is the case, under $1,000 is not a tier.
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#1559805 - 06/02/11 06:43 PM Re: Zero Interest rlcarey
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You would disclose that a minimum balance of $1,000 must be maintained in the amount each day to earn interest (or you could reference the tiers) and whether you pay interest on the entire balance or the portion in the tier (Tiering method A or B).
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