We currently offer variable rate IRAs for both Traditional and Roth that are invested in Savings accounts. We also offer fixed rate Traditional and Roth IRAs that are invested in CDs.

We have changed our core processor and there is not a product for IRAs to be invested into anything but CDs, so these accounts are essentially a forced account into the system. What makes these accounts variable rate is that the rates can change every 3-months, as opposed to our 12-month and 18-month CD IRAs.

With that background, I’d like to get thoughts on us creating a Fixed Rate 3-month IRA and converting all variable-rate IRAs to this product. This would still allow the rate to change every 3 months, but the manual maintenance would go away. Are we able to accomplish this change with a notice to the customer that includes new disclosures or are we required to get new signed documentation.

I’d appreciate any feedback you can provide.

You will owe each customer a TISA disclosure with the new product subject to the same advance notification requirements as the maturity notices and also you cannot change the account type until maturity for each account that has the old product.