Situation: New product development- A NOW account 100,000 minimum to open, 100,000 minimum balance to earn APY. This account would be calculated using the daily balance computation.
In the proposed DD TISA disclosure, there would be an additional terms section that states..."if at any time the statement cycle your balance falls below the minimum, no interest will be credited to your account for the statement cycle".
DD 230.7(a)(2)1-2; 4 is the citation area I am reviewing.
My interpretation is that interest accrued during the statement cycle for the days that the account met or exceeded the 100,000, the account must receive that accrued interest at the statement cycle completion. The "additional terms" statement as proposed, would be in error with DD.
Opinions?