We offer CDs that require a minimum opening deposit of $500. This $500 amount is the minimum balance required to obtain the APY.

According to 230.8, in an advertisement for a Certificate of Deposit where we advertise the APY, we are also required to state the "Minimum balance" (among other requirements).

I am interested in knowing how others disclose when the minimum opening deposit is the same as the minimum balance. In our ads we usually state "minimum Deposit of $500 to obtain APY", which for a CD usually means that it is the minimum balance.

I want to avoid any examiner criticism and feel that our logic makes sense, yet I know that logic sometimes does not come into play when discussing regulatory rules.

Any thoughts???

If the minimum opening deposit is not higher then the minimum balance to obtain the APY then we will just disclose the minimum balance to obtain the APY.

The regulation specifically says you only have to provide the minimum balance to open the account if it differs from the minimum balance to obtain the APY.

Thanks to you both -

John - I think that the problem that is faced here is that Marketing wants to state something like "$5000 minimum to open", which in reality is the minimum balance to obtain the APY and that is why they want to write the ad that way.

Do you think that there is no leeway in arguing this with an examiner?

Since you need to include the minimum to obtain the stated APY, and your marketing department wants to include the minumum to open the account, you could write both in one sentence. "The minumum balance required to open the account and obtain the stated APY is $500".

There is nothing preventing you from stating the minimum needed to open the account when it is the same as the APY, but you MUST state the minimum needed to obtain the APY.

Thanks for your help, I will pass this along to them.