If we wanted to promote a CD at 1.50% APY, but the actual APY on our system would be 1.51%, is there a way we could do this? Due to system calculation limitations we could not get the1.50% to work. They want to promote the even number of 1.50% to coincide with an anniversary.
I know there are tolerances in Reg. DD, but those are for errors, correct? Is there any way this could work? I wouldn't think a footnote with the actual APY would suffice, even if it is in the customer's benefit. Any thoughts would be appreciated. Thanks!