We have an savings acct that earns higher rates because of restrictions on the w/d. We want to consolidate these accounts into our money market account. The higher tiers will be at a lower interest rate. Since our disclosure say that we can change the rate at our discretion qtrly, is a 30 day notice required? Or can we change and notify at the same time?

Lu,
According to Reg DD, § 230.5 - Subsequent disclosures.
(a) Change in terms—(1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under §230.4(b) of this part if the change may reduce the annual percentage yield or adversely affect the consumer. The notice shall include the effective date of the change. The notice shall be mailed or delivered at least 30 calendar days before the effective date of the change.

From what you have stated, it appears that the change will result in lower interest rates for those customers at the higher tiers. To comply with Reg DD and avoid any UDAP problems, I would notify your customers of the change.
BC

I would think that since you disclose a variable you can do the rate change w/out 30 days notice but are other terms changing such as the restrictions you have on WD's and is that change adverse to the consumer thus requiring 30days notice.