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?

You mean you'll continue to pay interest below $100? If so, you could do a courtesy notification.

You mean you're going to stop paying interest below $100? If so, a notice should absolutely be sent since you will be discontinuing an established practice.