I could use some opinions, please. I am doing my Reg dd Audit, and have come across some 18 month and 30 month variable rate IRA, that are very old. They list both a minimun and a maximun rate. As far as I can tell, they have never been redisclosed with a new floor or ceiling rate(the floor rates originally run from 5 to 8%). The only disclosure given at the time of renewal is as follows: "At our discretion, we may change the interest rate on the account September 1 and March 1 of each year." Needless to say, our rates now are well below the floor rate. I do not feel that the above disclosure is sufficient, but I would like other opinions.

I would consult legal counsel. If you did not properly extinguish the rate floors from a contractual point of view, you are ripe for a class action lawsuit for back interest. This is a contractual matter at this point and I wouldn't be too concerned with the Reg DD implications. That is not where the greatest risk of penalty lies.

Thank you so much for the advice. I did not think of checking with our attorney. I did however notify management of the possibility of having to refigure and re-emburse for interest not paid. I appreciate the conformation that this could be a very BIG problem.