reg DD states an institution should use the same method to determine any mimimum balance required to eran interest as it uses to determine the balance on which interest is calculated..
so, if we use daily balance method to calculate the interest, does that mean, we need to require a minimum balance to eran interest on a daily basis..
e.g., you must maintain a minimum balance of $ XX each day to obtain the APY?
we are introducing new products, and I want to make sure we disclose this right...
mgmt. wanted to intorduce a product where, the interest will accrue on a daily basis- by daily balance method,,, but at the end of the statement cycle, if the average available( collected) balance falls below a minimum , we were not gonna pay interest...
reading Reg DD, I think the minimum balance to earn interest also needs to be stated on a daily basis..
please give advise.. thank you...

We state in our TIS disclosure "You must maintain a minimum balance of $100.00 in the account each day to obtain the disclosed annual percentage yield." Therefore, you go below the minimum once during the month, and you lose the interest for the month.

Any requirement to disclose the computation method on non-consumer accounts?

Not sure you can do this "not pay interest for the month" unless you are using the average daily balance method.

From the Regulation DD Commentary:

(a)(2) Determination of minimum balance to earn interest
1. Daily balance accounts. Institutions that require a minimum balance may choose not to pay interest for days when the balance drops below the required minimum, if they use the daily balance method to calculate interest.
2. Average daily balance accounts. Institutions that require a minimum balance may choose not to pay interest for the period in which the balance drops below the required minimum, if they use the average daily balance method to calculate interest.

Oops! Thanx Steve! I went back and checked this out with our ops officer, and I was wrong in my prior post. We do not dock the customer for the entire month's interest, only the days they go below the minimum. I need to recheck our disclosure. The wording could be taken either way. But we do what is in the best interest of the customer.