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#2273486 - 07/27/22 08:40 PM Changing MMA to a tiered rate account
almbanker Offline
Junior Member
Joined: Nov 2015
Posts: 36
Our Money Market Account is currently not tiered but it is disclosed as a variable rate account. Management is considering making this a tiered rate account. Will this require us to send a 30 day notice to existing account holders?

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#2273491 - 07/27/22 08:59 PM Re: Changing MMA to a tiered rate account almbanker
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,618
Galveston, TX
Yes, Tiering is a require disclosure under 1030.4

3. Tiered-rate accounts. Each interest rate, along with the corresponding annual percentage yield for each specified balance level (or range of annual percentage yields, if appropriate), must be disclosed for tiered-rate accounts. (See Appendix A, Part I, Paragraph D.)
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#2273517 - 07/28/22 02:11 PM Re: Changing MMA to a tiered rate account almbanker
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Because adopting tiering has the potential for lowering the rate that is paid to some depositors, you need to provide 30 days' advance notice before making the change. And, of course, you will need to update your TISA account disclosures for these accounts.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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