The clock does not start until the first renewable date (regardless if automatic); So if there is no customer activity on the account from the date of the renewal date; the clock starts. Then the CD is escheatable at 3 or 5 years based on the state. However, do not break the next cycle and charge fees; therefore a 5-year CD will be escheatable to a 3-year state 5 years after the first renewal if no activity.
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Debbie Zumoff
Chief Compliance Officer
Keane Unclaimed Property
www.keaneup.com