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#1123890 - 02/05/09 06:33 PM Reg DD and Maturity Notices for CD's 1 yr and over
Confused in Compliance Offline
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Joined: Apr 2002
Posts: 228
We are currently working to streamline out maturity notice process and when speaking to one of our vendors we were told that other banks are not sending out the full account disclosures anymore because it's not necessary. I checked Reg DD and do not see a change. Is there something I am missing? Does everyone else mail out the full account disclosure with the renewal notice for CD's over 1 year?

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#1123915 - 02/05/09 06:47 PM Re: Reg DD and Maturity Notices for CD's 1 yr and over Confused in Compliance
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
Full disclosures are still required. We were also told that other banks are not sending full disclosures on CD's with maturity greater than 1 year. It still doesn't make it right.

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#1123924 - 02/05/09 06:54 PM Re: Reg DD and Maturity Notices for CD's 1 yr and over AuditorK
Milby Offline
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Joined: Apr 2007
Posts: 953
Tejas
What is to disclose if the terms have not changed? If your accounts are auto-renewal and your disclosure states that the rate will change to the then-current rate, there is no need to re-disclose.

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#1123965 - 02/05/09 07:19 PM Re: Reg DD and Maturity Notices for CD's 1 yr and over Milby
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
Reg DD, Section 230.5(b)(1) (notices before time account maturity).

For automatically renewable CD's with maturity greater than one year, the maturity notice that is sent out for the existing account must include or be accompanied by full new account disclosures (everything listed in 230.4(b)) on the account that will be renewed at maturity of the original CD?

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#1124056 - 02/05/09 08:09 PM Re: Reg DD and Maturity Notices for CD's 1 yr and over AuditorK
BrendaC Offline
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Sweet Home AL
In my prior life, we were able to modify our renewal notice to create a full page notice that complied with requirements. Perhaps some of these individuals don't realize that they may be handling another way and not actually mailing a traditional TISA.
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#1124094 - 02/05/09 08:29 PM Re: Reg DD and Maturity Notices for CD's 1 yr and over BrendaC
AuditorK Offline
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Posts: 962
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As BrendaC has said, we utilize a full page maturity notice that contains all the terms required to be disclosed. We don't send a full TISA disclosure along with the maturity notice.

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#1124114 - 02/05/09 08:42 PM Re: Reg DD and Maturity Notices for CD's 1 yr and over AuditorK
Skittles Offline
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TN
We have put the 'standard' language on the back of our statement paper - early withdrawal penalty, minimum amount to open, etc.
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#1125602 - 02/07/09 10:58 AM Re: Reg DD and Maturity Notices for CD's 1 yr and over Confused in Compliance
Elwood P. Dowd Offline
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Next to Harvey
Reg DD does not require that all disclosures be on the same piece of paper... Some banks enclose a new initial disclosure with the maturity notice generated by their computer system.
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