Good morning,
We are looking to offer a blended variable rate checking and savings account. Reg. DD requires us to disclose an APY range for the blended rate on the TISA disclosure. Our core system allows for dynamic filling of rates/APYs; however, does not work for the blended APY range. We do not want to update our TISA disclosure every time the rate changes so are trying to come up with an alternative method of disclosing the APY range. We do not have a rate sheet so this is not an option. I would like to talk to other banks offering blended rate accounts to see how they handle disclosing.