So, TIS states that "Certificate of Deposit" is a bank product while "Share Certificate" is the credit union version.
We are a CU and we have CD's. We call them that, they're labled as such, everything about it says Certificate of Deposit. One of our subscriptions for legal counsel sent out an article on this (website compliance specifically) that got me thinking. All of our major competitors in the area (most of them significantly larger than us) have them listed as CD's on their websites, so my case that we need to change it will certainly be met with opposition (we've always done it this way, and nobody else does it that way, why should we?).
Any other CU types out there with any experience on this?
From the Official Staff Interpretations on TISA from NCUA:
link 5. Use of synonyms. Generally, it is not the purpose of part 707 to prohibit specific descriptive terms for accounts. For example, credit unions can use adjectives and trade names to describe accounts such as “Best Share Draft Account,” or “Ultra Money Market Share Account.” Synonyms for share, share draft, money market share, and term share accounts may be used to describe various types of credit union share and deposit accounts as long as the synonym is accurate and not misleading and, for account disclosures, is used in conjunction with the correct legal term. For example, the following synonyms may be used:
i. The term “checking account” may be used to describe share draft accounts.
ii. The term “money market account” may be used to describe money market share accounts.
iii. The term “savings account” may be used to describe regular share and share accounts.
iv. The terms “share certificate,” “certificate account,” or “certificate” may be used to describe share certificates and other dividend-bearing term share accounts.
v. However, under no circumstances may a credit union describe a share account as a deposit account, or vice versa. For example, the term “certificate of deposit” or “CD” may not be used to describe share certificates and other dividend-bearing term share accounts. Similarly, the terms “time account” (used in Regulation DD, 12 CFR 230.2(u)) and “time deposit” (used in Regulation D, 12 CFR 204.2(c)) may not be used to describe term share accounts.