For variable-rate accounts do both of these phrases have to be on the TISA disclosure? or will one suffice.

Determination of Rate: At our discretion, we may change the interest rate on your account.

Frequency of Rate Change: We may change the interest rate on your account at any time.

Reg. DD 1030.4 (b) - also see the commentary.

(b) Content of account disclosures. Account disclosures shall include the following, as applicable:

(1) Rate information. (i) Annual percentage yield and interest rate. The "annual percentage yield" and the "interest rate," using those terms, and for fixed-rate accounts the period of time the interest rate will be in effect.

(ii) Variable rates. For variable-rate accounts:

(A) The fact that the interest rate and annual percentage yield may change;

(B) How the interest rate is determined;

(C) The frequency with which the interest rate may change; and

(D) Any limitation on the amount the interest rate may change.

Some might feel that "at our discretion" includes the element of timing. However, to be sure you cover both requirements, you might consider combining the required statements: "At our discretion we may change the interest rate and annual percentage yield on your account at any time."

Kathleen & John, thanks for the input.

TISA disclosures for non-automatically time account states

" This account will not renew automatically at maturity. If you do not renew the account, your deposit will cease to earn interest at maturity."

Does it also need to state "your deposit will be placed in (an interest-bearing/a noninterest bearing) account? Also does it need to state "This account requires the distribution of interest and does not allow interest to remain in the account."