Answer:
The original disclosure would suffice. It would be no different than any other variable rate product for which you would not redisclose every time the rate changed.
First published on BankersOnline.com 4/05/10
Bump-up Rate CD
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Question:
We are thinking about offering a "bump-up" rate CD product. If we do, I know we need to include in the original TISA disclosure the terms of and conditions of the product to the customer, but at the time the customer exercises his right to "bump" the interest rate on the CD, do we need to provide him/her with a new TISA disclosure reflecting the new rate/APY or does the original TISA disclosure suffice, even though the rate/APY will not be the same?
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