We are updating the format of our Disclosure of Account Terms for Certificates of Deposit. When we prepare a Certificate, we type on the CD that the customer gets the term, the rate, and the APY. We also type on the customer's CD if the interest is paid to this account, deposited directly to a savings account and the number, or mailed. In addition we actually check off on the CD itself if interst is paid monthly, quarterly, semi-annually or at maturity. We show all this information on the CD the customer takes along.

But our Disclosure of Account Terms folder has us hand enter all this information again not only once but twice. One time under the Certificates of Deposit section which also outlines the Compounding, Crediting, Minimum Balance etc. And then a second time on the back of the brochure under "Your Account" which begins with "These are the accounts you have opened or inquired about. Further details about these accounts are inside this brochure." And then the term, rate, yield, etc is filled in again.

I'm not in Banking that long and I know there are a lot of regulations, but this type of redundancy seems unnecessary and opens up the possibility of error in hand entering the information several times. Since we actually enter all the information on the CD itself, must the same information be entered again on the Disclosure? Or can the Disclosure be generic with of course all the preprinted disclosure of various account general information and we don't have to take the time to handwrite the specific term and rate etc in the Disclosure as long as it is clearly on the CD.

Thanks for any input.

This does sound redundant. You only need to provide the information once. I don't understand why you would need to complete the info twice on the same document. Without seeing all of the documents, it is difficult for me to tell you exactly what to do.

TISA does requires the disclosures to be retained by the customer. If you only list the TISA info. on the CD and the customer presents the CD to you at maturity, they have to be able to get a copy of the CD to meet the retention requirement. However, I know of numerous banks that mark the CD paid and then photocopy the CD for the customer to meet this requirement.

You may want to compare your CD disclosures to the regulatory requirements in §230.4(b)

Because of some technical omissions on some of our CD forms, we had to provide a separate TISA to cover all Reg DD required information on our IRA accounts for years. We were able to comply by using only one form on our "regular" CDs, but we had to "trick" our prior system to print only CD receipts since we offer paperless CDs.

Bottom line--Get with your forms provider to make sure that you understand your forms options, compare options available to you to Reg DD rules and system requirements and you can likely streamline your process.