We offer CDARS to our municipal customers and have begun offering it to our consumer customers as well. Do we just need to just give our regular TISA disclosures to the consumers? Do we need to keep a copy of their contract with their interest rate, APY etc.?

We have not started our CDARS program yet however from the way it was explained to us, I don't believe you would. Have you contacted your representative yet?

The representative informed me they have the program in 1,400 banks and it is in compliance. They do have a TISA compliant contract, however, my employees have not been filling it out completely or keep copies of all of them. For example, APY's are not always on the contract etc. and I do not have copies of all the consumer contracts to verify those.