We are wanting to offer a one year certificate of deposit that pays the interest "up front". I have attempted to think of all of the compliance requirements but am not sure if I have missed anything. We will not cut the check until the 20th day to ensure that nothing is paid in the first 7 days and also ensure that the deposited item is not returned nonsufficient plus the Truth in Savings issues. Is there anything else that I am missing?

Connect with your bank's tax advisor on the 1099 issues. You are creating an OID vehicle, and you may have some special reporting considerations.

Thanks, We discussed the 1099 issues that it would be income to the customer in the year it was paid but didn't think any further as I am not familiar with OID