I'm new to deposit compliance and I have a TIS question. Bank wants to offer a CD w/ a rate for 90 days after that the rate will change. (The rate will be unknown at the time of initial disclosure.) Is this considered a variable rate with only one change after 90 days and we initially disclose as such? Or would this need a subsequent disclosure prior to the 90 day change?

Forgive my ignorance, I'm just a mortgage gal at heart.

This is a variable rate CD and will need to be disclosed as such. If you set it up as a variable rate CD, no subsequent disclosures will be necessary. Honestly, I have never seen one of these, but you can be the first.

Thanks for your help.

Maybe we're trying to be innovative and complex only we aren't doing it for the right Reg!

If you are tying your rate(s) to any type of index, you want to disclose that fact as well. Depending on the specific structure of the product, you could have a stepped-rate product.