Good morning,
Our Management Team is running certificate special which allows for a higher rate for new money. When the special began new money was defined as bank-to-bank transfers, cash deposits, checks deposited from another financial institution, and wire transfers. They are finding current members are withdrawing their money, depositing into another bank and then bringing it back two days later. I know, surprise right? To combat this, they now want to include the following statement in their disclosures. Existing money transferred from our institutions account and brought back to qualify as new money must be out of the account for at least thirty (30) days. Account balance histories will be utilized to verify the qualification of earning the higher yield. My question is, is this a UDAPP violation? Can we make changes to the definition of new money midstream?