I'm certain I'm over thinking this, but thought I would ask the group:
Sr. Management and Accounting are interested in offering a lower MMA rate for new accounts than is offered for currently open MMA accounts.
The idea is to slow deposit growth without losing the current deposit base.
They would like to use the same MMA product we are offering but we will have to code it differently in our core so the rates can be properly applied.
Would having a different code in the core trigger this as a new product in an examiners eyes?

Other than tracking to insure no one's "good customer" gets put on the higher rate, what concerns would you have?

Thanks for your help

Anytime you set up a new product code in your core, there is risk that the service fees, interest rates, compounding/crediting, etc. could be set up incorrectly. As an auditor, when I am testing for potential Reg DD / UDAAP issues, I am always interested in new product codes. If I test the existing money market and find no issues, that doesn't mean that all money markets are in compliance. As part of your change management processes, you should test your system after the product code is established to ensure that all the parameters match your disclosures and advertising.

I'll second what Brian said. New product codes, overrides, and "special" accounts.

Add to the above that you need to handle this based of stated parameters. That is, can an existing customer open a new MMA at the old (higher) rate? Can an existing MMA customer split their account into 2 at the higher rate? Can the existing MMA customer add someone to their account, and then have themselves removed from it? What about a split of the account in the event of a divorce? In the case of a POD, do they keep that rate, they just suffered a tragic loss after all (they said as they wanted that rate?)

I think there are many issues to consider as well as the market in your area, but it's not a "fair banking" issue if that's what your asking about. The reasons for the rate differences make sense.