Skip to content
GeoDataVision
Thread Options
#1842810 - 08/15/13 03:46 PM CD Pre-Maturity Notices and Disclosures
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
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?
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

Return to Top
Deposits and Payments
#1842824 - 08/15/13 04:14 PM Re: CD Pre-Maturity Notices and Disclosures Kelsey D
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
The impending maturity notice and the stuffer together constitute the notice required by the regulation. I see nothing wrong with referring to the other document in the mailing. What you can't do is refer to the new maturity date in a manner like "24 months from the current maturity date." You have to cite the specific date within the mailing.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1842831 - 08/15/13 04:25 PM Re: CD Pre-Maturity Notices and Disclosures Kelsey D
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Thank you, John! Happy Birthday!
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

Return to Top

Moderator:  John Burnett