And, of course, if you don't require that interest be paid or compounded at least annually, the APY on the account will be lower than the interest rate. When market rates are higher, this might make a difference to depositors who will want an explanation of this phenomenon. In today's rate environment, it's largely a non-issue.
Which brings me back to the original question. Let's understand that payment of interest on a CD can include payment to the CD itself a/k/a compounding or payment out (check or to another account, for example). Either of these on an annual or more frequent basis will avoid the OID issue and the depressed APY issue, too.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8