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CD renewal disclosures; Construction loans & RESPA

Question: What do we have to include in CD renewal disclosures?

Answer: If the CD will renew automatically and the term of the CD is for more than one year, you must include all of the disclosures listed in 230.4(b) and the date the certificate matures. 230.4(b) is the new account disclosure laundry list. So effectively, 230.5(b) requires new account disclosures for automatically renewable CDs with a term of more than one year. Leaving these disclosures out of renewal notices is a common violation.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 7, 7/03

First published on 07/01/2003

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