We have stated an APY for a CD promotion ad. The CD does not have any maintenance or activity fees tied to the account, except the early withdrawal penalty. Would the early withdrawal penalty be considered a maintenance fee? Is the statement "fees may reduce the earnings on the account" required?

IMO, no. We do not include "fees may reduce earnings" verbiage on an ad for our CD's.

You would have to state that an early withdrawal fee applies per Reg DD, however, upon inspection of the sample advertisements in the language I agree with P*Q that "fees may reduce earnings" is not required if no other fees are applicable.

Great, thank you for your input.