Our company is wanting to offer Time Deposit accounts. I have read Reg. DD and I see that Time Deposits have certain restrictions on withdrawal periods and penalties but I don't think they are much different than Certificate of Deposits and Auto Save IRA CD's. Basically if we adhere to TISA requirements are we okay to offer these or should I be looking into any other regs or requirements?
Are Reg DD disclosures, especially the APY required when, for example, a customer negotiates a bumped up rate for 3 months?
If we discontinue a debit cash back rewards program are we required to provide notice to the customer within a specified time frame, and are we required to notify them at all?
We are moving our accounts to a relationship style checking with service charge refunds with certain transactional behavior.(ACH, POS, eStatements,etc) What are some considerations we need to remember when building the TIS disclosures?
I have been instructed to lead a project around compliance ramifications if negative interest rates were to occur in the US. With regard to deposit accounts, would all TISA and other initial disclosures need to be updated to reflect this change. Since the change in terms would negatively affect our customers. This would be quite an undertaking as we have 10 member banks. Would all of our advertisements have to be re-disclosed? Any feedback is greatly appreciated.
We use a third-party service provider to manage some of the benefits of our “Platinum Account”. Are there possible UDAAP issues lurking here?
If you stop offering the ability to write checks from your money market account, what disclosures or notice must you give to your customers?
In order to have a NOW account, does the account contract have to disclose the reservation of the right at any time to require not less than 7 days notice in writing before any withdrawal from an interest bearing account?
Does an excessive withdrawal fee need to be disclosed on the TISA if it is not an automatic fee? The bank has the option to charge it or not. Would it be considered an incidental fee in this case?
Under 12 CFR 230 (Regulation DD), it discloses Truth in Savings disclosure requirements. I am wondering if an IRA is considered a time deposit account, and if a TIS disclosure is required for an IRA.