In going thru our last Reg DD audit, we are having the discussion on a tierred rate accounts. The bottom tier does not pay interest; therefore is not listed on the rate sheets or website. Compliance says since it is a tier, it needs to be listed irregardless of the fact that the interest rate is 0%.
We have not been questioned on it by the regulators since the accounts were begun some number of years ago.
Which is correct?
Thanks for your help.

Commentary 230.4(b)(1)(i):

3. Tiered-rate accounts. Each interest rate, along with the corresponding annual percentage yield for each specified balance level (or range of annual percentage yields, if appropriate), must be disclosed for tiered-rate accounts.

Just because you choose to pay 0.00% on one of the tiers, I don't see any provision that would allow you not to disclose that tier.

I would agree with Randy. Remember that the intent of Reg DD is to inform the consumer. In this case you want to tell them that balances of up to $X will not earn interest. It is a tier.

Thanks. I guess my confusion comes from fixed rate vs tiered rate. On fixed rate accounts you only have to specify the APY and the minimum balance to earn interest. You do not have to specify otherwise you earn no interest. Therefore on tiered rate accounts, I specify the APY and the minimum balance for each tier and not the tier for the one that does not earn interest.