We advertised a 5.20% APY without the “variable” qualifier, and the model caught it before legal did.
Earn up to 5.20% APY on balances over $10,000 — substantially more than the national average.[¹]
Marketing of deposit products requires the FDIC membership statement adjacent to the rate claim.
APY can change after account opening — must be disclosed within the same sentence or asterisked footnote.
FDIC National Rates and Rate Caps, updated 2026-05-19. Footnote inserted.