I just determined that we are paying interest on IRA CDs no matter the balance. So even though there is a minimum balance to open the account, if the balance goes below that amount, we still pay interest. Unfortunately the IRA CD TIS says that the account must have a minimum balance of $100 to earn interest. Thankfully, we haven't harmed the customer since we are paying on balances below that. However, do we need to redisclose a TIS to any customer who received a TIS with the incorrect wording?
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