Yes...this is a strange question. Who spiked management's eggnog?!?
I would think for new accounts, the TISA would need to be based on the offered rate. If they want to pay more to existing account holders, I would not think an explanation would be necessary...but if I were going to do this...I think I would at least have to turn in to some PR piece....otherwise it's like..what IS the POINT?!?
My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour