Let's say John Smith has a CD for 1 yr @ 3%.

He comes into the bank and tells us that he can go down to ABC Bank and earn 3.5% -

To keep the customer, we raise his rate to 3.5%

Now, here is my question. If he had a fixed rate CD - can we do this? Should we provide a new TISA with the APY stated.

In my mind I'm thinking it's a benefit to the customer - therefore, no disclosures required.

You are correct.

thanks a million !