That is a horse, as they say, of a different color. If, for example, you have a 0% tier from $0 to $1,000 and pay 0.10% APY on balances above $1,000, you aren't failing to pay interest on the "reserve" portion of the balance. And, as Appendix A to Regulation DD points out, your interest could, using tiering method B, only apply to the portions of the balance above $1,000, so that the actual APY for the upper tier would be in a range starting at 0.00% and approaching 0.10% as balances increased.
It may be a subtle difference, but it is a difference.
Last edited by John Burnett; 08/28/12 02:12 PM. Reason: clarity
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8