While I agree that changing from a single rate to a tiered rate requires additional disclosure, a critical question is whether that additional disclosure needs to take place 30 days in advance of the change. That will depend on whether the change adversely impacts the consumer. If balances over $100 up to whatever the cap is for that tier will still earn at least 3.1% APY, I don't think you would need to provide 30 days advance notice. You would still be required to disclose the change to a tiered account, but if I had $200 in one of these accounts before the change earning 3.1%, and now after the change I'm still earning 3.1% I have not been adversely affected. The fact that someone else who had $10,000 in the account and was earning 3.1% before the change and is now earning 4.5% because they're in a higher tier is not an adverse impact on me and is not a trigger for advance disclosure.
Jim Bedsole, CRCM, CBA, CFSA
Opinions expressed are my own, and do not necessarily reflect those of my employer.