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#113343 - 09/09/03 02:45 PM disclosure question
Anonymous
Unregistered

we offer a feature on our CDs called " emergencyy funds withdrawal option". Withdrawals must not take place within 6 days of purchase or the last withdraw date.. One free withdrawal per year per customer houshold.
MY question is, do we have to disclose this under Reg DD?
Thanks for your help

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Operations Compliance
#113344 - 09/09/03 02:51 PM Re: disclosure question
Jello Offline
100 Club
Jello
Joined: Feb 2003
Posts: 162
I think you have to disclose it. Under 230.4(b)(6)(ii) you have to disclose if an early withdrawl penalty will be imposed, how it is calculated, and the conditions for its assessment.
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My opinions are not that of my employer and are not legal advice, they really have no value at all.

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#113345 - 09/09/03 04:43 PM Re: disclosure question
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
You likely disclose the penalty already. I do not believe you have to disclose that under some circumstances you will waive the fee. That is what you are doing.
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AndyZ CRCM
My opinions are not necessarily my employers.
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