We want to offer a Step-up CD that has a known rate to start with and we know the rate it is going to step up to. For disclsoure purposes would you consider this a variable or fixed rate CD. The rate will change in six months but we have already disclosed what it will change to and it will be fixed for the remainder of the term.

For Call Report purposose, RC-E-13 (12/2008) says:
A fixed interest rate is a rate that is specified at the origination of the transaction, is fixed and invariable during the term of the time deposit, and is known to both the bank and the depositor. Also treated as a fixed interest rate is a predetermined interest rate which is a rate that changes during the term of the time deposit on a predetermined basis, with the exact rate of interest over the life of the time deposit known with certainty to both the bank and the depositor when the time deposit is acquired.

Regulation DD has a separate definition for a "Stepped Rate Account" And the APY calculation is a little different for those accounts in appendix A, and there are some different Model Clauses in Appendix B1. There are also a few entries in the Official Staff Commentary.

230.2(s) Stepped-rate account means an account that has two or more interest rates that take effect in succeeding periods and are known when the account is opened.

Variable Rate