My question is in regards to determining if we disclose this account as a fixed rate account or a variable rate account.
Reg DD defines a fixed rate account as -- (l) Fixed-rate account means an account for which the institution contracts to give at least 30 calendar days advance written notice of decreases in the interest rate.
We have an account classified as a fixed rate account; however, we also include this statement in the Reg DD TISA disclosure, "You can exercise your option to increase the rate on your certificate once during the term of the certificate. Any increase in the rate will affect earnings. It is your responsibility to watch for any increases in rates and to notify us in writing of your intent to increase the rate on your certificate."
If the interest rate can increase at the consumer's request should this be a variable-rate account instead of a fixed rate account or since we, the bank, do not increase the rate at anytime on our own is it ok to be a fixed rate account??
Thank you!
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