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#1730567 - 08/14/12 02:44 PM Truth in Savings Disclosure for renewed CDs
Lilly C Offline
100 Club
Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
When we open a new CD we provide a TIS. They get their maturing notices and their renewal notices. Do you provide a new TIS disclosure with new information for the CDS (over a year) blushthat are automatically renewed? In a recent FDIC exam we were told we need to provide one. The one we have is more for new cds. Is there such a thing as a TIS for renewed CDs. Can anyone provide a sample? Help crazy

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#1730604 - 08/14/12 03:42 PM Re: Truth in Savings Disclosure for renewed CDs Lilly C
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The regulation says, "If the maturity is longer than one year, the institution shall provide account disclosures set forth in Sec. 1030.4(b) of this part for the new account, along with the date the existing account matures. If the interest rate and annual percentage yield that will be paid for the new account are unknown when disclosures are provided, the institution shall state that those rates have not yet been determined, the date when they will be determined, and a telephone number consumers may call to obtain the interest rate and the annual percentage yield that will be paid for the new account."

Those account disclosures under 1005.4 are the full disclosures given at account opening. You may have them in an omnibus disclosure pamphlet covering other accounts in addition to the CD in question.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1730833 - 08/14/12 08:33 PM Re: Truth in Savings Disclosure for renewed CDs Lilly C
Lilly C Offline
100 Club
Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
Thank you so much, John. We have been giving the customers the wrong/incomplete information.

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