We are in the process of acquiring another financial institution and working on the communication to the acquired customers. We have mapped the target bank customers into deposit accounts at our bank, which may have different features and rates/tiers than their existing product at the target bank. We are having a debate as to whether we need to disclose the interest rate & APY to these clients as part of our disclosures to them along with other TISA & Reg. E disclosures. The rates at the target bank and the rates at our bank are variable and subject to change at our discretion. Staff in the deposit business line has worked at other larger FIs in the past and have provided examples of their communication packets that do not include rate, just a statemen that the account pays interest and is variable. Does anyone have any thoughts or experience with this?

"We are having a debate as to whether we need to disclose the interest rate & APY to these clients as part of our disclosures to them along with other TISA & Reg. E disclosures. The rates at the target bank and the rates at our bank are variable and subject to change at our discretion."

Not sure how you could possibly include the interest rate and APY. I think that normally, you would disclose the fact that the rates are variable and give a phone number for them to call to obtain current rate information on the targeted conversion account.