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#1528199 - 03/29/11 03:53 PM EFT Disclosure
mzachau, CRCM Offline
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mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
Our certificate of deposits are autorenewal but the customer has the option to pick a different term and the end of the term of their existing CD.

If a customer elects to go from a 12month to 24month CD and there is a difference in the EFT disclosure for the two terms, is it acceptable to only provide the customer a notice of the changes to their existing EFT disclosure, or is a new EFT required?

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Operations Compliance
#1528216 - 03/29/11 04:10 PM Re: EFT Disclosure mzachau, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,005
Galveston, TX
Why would you be delivering an EFT disclosure on a CD in the first place and what possibly could vary based on the term of the CD?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1528233 - 03/29/11 04:32 PM Re: EFT Disclosure rlcarey
mzachau, CRCM Offline
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mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
We have one CD product that allows for deposits to be made throughout the term of the CD. This is the only difference between any of our CD's.

Our customers have the ability to perform electronic transfers during their grace period on all CD's, so we provide the disclosure at account opening.
Last edited by mzachau; 03/29/11 04:38 PM.
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#1528253 - 03/29/11 05:02 PM Re: EFT Disclosure mzachau, CRCM
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,005
Galveston, TX
Transfers to and from outside the bank? Along with providing monthly periodic statements on all these CDs??
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1528286 - 03/29/11 05:30 PM Re: EFT Disclosure rlcarey
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
Yes, the customer may transfer funds to and from the bank. We have accounts on quarterly statement cycles, and utilize interim statements any time EFT's are transacted on the account during non-statement periods.

We provide this access because we are a single branch location and need to allow for additional access to funds due to the limited number of locations for our customers.

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#1528301 - 03/29/11 05:39 PM Re: EFT Disclosure mzachau, CRCM
Georgia Plum
Unregistered

You actually allow EFT debits against a CD?? Wow. Isn't that a huge risk? How do you limit it only to the grace period? What prevents them from making an EFT transfer during the term of the CD?

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#1528311 - 03/29/11 05:49 PM Re: EFT Disclosure
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
Our core processor restricts debits from our CD's during the term of the CD. It is all triggered by whether a early withdrawal penalty would apply. The system drops the EWP during the 10 days grace period.

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