I think our process is very similar to most banks when it comes to renewing CDs. Our core system generates an approaching renewal notice that includes the current and new maturity dates. We mail the notice along with a one-page stuffer that has the full TIS disclosures. I'd like to avoid having to fill in anything on the disclosure. So...
1) Where we state that the rate and APY will be available on [date], can I just refer to the current maturity date on the renewal notice instead of typing in the date?
2) Where we state that the new certificate will mature on [date], can I just refer to the new maturity date on the renewal notice instead of typing in the date?
Nothing else on the disclosure is account specific, so referring to the renewal notice will eliminate customization.
Thoughts?
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.