We currently disclose our savings accounts as variable rate accounts with a rate that may change at the bank's discretion. Do we need to provide 30 day advance notice before reducing the interest rate paid on savings accounts? I'm having a brain freeze.

nope

You've already put your customers on notice that the rate may change. Most variable rates are disclosed as subject to change at any time at the discretion of the bank. If you disclosed any restrictions as to when a rate could change or by how much, you need to follow those, otherwise, you're good to go.

No.

• For variable-rate accounts—A variable-rate account is an account for which the interest rate may change after the account is opened, unless the institution contracts to give at least thirty calendar days’ advance written notice of a rate decrease. Variable-rate accounts include those for which the rate change is determined by reference to an index, by use of a formula, or merely at the discretion of the institution. If an institution offers variable-rate accounts, it must disclose the following:

– That the interest rate and annual percentage yield may change
– How the interest rate is determined
- If an institution reserves the right to change rates and does not tie changes to an index, it must disclose the fact that rate changes are solely within the institution’s discretion.
– The frequency with which the interest rate may change
- An institution that reserves the right to change rates at any time must state that fact.
– Any limit on the amount the interest rate will change at any one time or during a specified period

And also......

Subsequent Disclosures
Notices of a Change in Terms

If an institution changes a term that is required to be disclosed for an account and the change might reduce the annual percentage yield or otherwise adversely affect consumers, the institution must send a written notice thirty calendar days before the effective date of the change. Institutions are not required to send rate-change notices for variable rate accounts or for time accounts with maturities of one month or less. In addition, institutions are not required to send change-in-terms notices in connection with an increase in check-printing fees.