Our xmas clubs end each year in October. We start opening Nov 1 and continue until the end of the year. Each a client is assigned a new account number. This year if a client wants to continue we are going to use the same account number and use the same signature card from last year. However, we are making a change to the program and require that the balances will be paid into an account instead of by check. The client will need to come in and start the club, just verify information and make a payment and they will be provided with a new TISA at that time explaing the details. Would we be required to provide a 30 day notice under TISA?

Would we be required to provide a 30 day notice under TISA?

I think it depends if your contract is only for one year or if it continues from year to year. If the contract terminates, it is a new account regardless of how you handle it operationally and you would give them a new disclosure when they open the new club account. If there is no maturity date, then a change of terms would be required. It may also depend whether or not this is classified as a savings account or time deposit.

Go to the commentary:

http://www.bankersonline.com/regs/230/regddcomm.html

Search for every time the word "club" appears and it should give you some additional guidance.

At my prior bank, we paid out our Christmas Club accounts on 10/31 each year by check or transfer to a specified account. The account remained open until January 31. If any deposit was made into the account between 11/1 and 1/30, the account remained active. If no deposit was made, the account closed 1/31. Customers loved it and we saved alot of wasted time at the new account desk.