We are going to start offering a step up CD. If at any time during the term of the CD the rates go up we will allow the customer, 1 time, to opt for the higher rate.
My question, do we have to send new disclosures, or can we simply make the necessary changes on the computer on the bank's end? The customer is getting the disclosures at the inception of the account. Until the rates increase, we wouldn't know what the new rate would be and this is to the benefit of the customer, not to their detriment. What do we need to do???