Hello BOLers,

I'm wondering if anyone would be willing to share how they facilitate this. How do you accomplish the requirement that you furnish TIS disclosure information on your CD's that automatically renew? Do you actually mail a formal TIS disclosure or do you incorporate the requirements into your renewal notice (examples if so...)?

Maturities longer than one year (§ 1030.5(b)(1))
If the maturity is longer than one year, the institution must provide the date the existing account matures and the required account disclosures for a new account, as described in section 1030.4(b). If the interest rate and annual percentage yield that will be paid for the new account are unknown when disclosures are provided, the institution must state:
That those rates have not yet been determined;
• The date when they will be determined; and
• A telephone number for consumers to call to obtain the interest rate and the annual percentage yield for the new account.

We have a daily report that shows the automatic renewals and their terms, rates, etc. I review that report every day and if there is a cd for longer than one year I then print out a new disclosure and mail it to the customer. I wish this was an automated process but unfortunately it isn't for us. We use FIS.

We decided (at my last bank) that we'd enclose a full CD disclosure document regardless of the CD term.

We recently ran into the same issue. Our president suggested that we just issue a CD Disclosure annually when we issue our annual notices and privacy notice. I told them I didn't feel comfortable doing it this way because there isn't any information disclosed regarding their CD. Managements arguement was that they receive that information on the notice so as long as the CD disclosure is provided we should be covered. What are your thoughts on this?

My thoughts are that management ought to stick to managing and not mess around with disclosures the timing of which is mandated in the regulation.

[Note: Those are my thoughts. I'd phrase it a bit more delicately when I responded to management's suggestion. The first time I had to bite my tongue in a similar situation was when a member of senior management suggested that he'd like to work on the teller line for a day.]

I thought maybe I had missed something after the issue was pressed! Glad to know I'm not losing my mind! Thanks!

We have the full disclosure (using the model language from the appendix) on the renewal notices for CDs greater than a year. We use Jack Henry and they have two separate notices depending on the term.

In looking for something else, I ran across this. Had been planning to ask the question anyway, this is better.

As a consultant for multiple banks, I am now running into this issue where the CDs with terms greater than 1 year do not have the full required disclosure. Most banks seem to be handling manually as indicated above.

But there is one Bank that is just too large to do it manually. Has anyone got any ideas or solutions in how they have handled the expanded disclosure?

Or maybe they have some kind of exemption that we just aren't aware of??? I am not calling out any vendors on this, but I have to wonder how a core processor doesn't have this in the system. Possibly the bank just doesn't have a correct setting in their system? HELP

Feel free to pm me if we need to discuss privately.
Thanks,

If there are any exemptions, I haven't heard of them. There is no provision for them in the regulation. Just a guess, but it's not unheard of that examiners miss this sort of problem because Reg DD isn't a high priority and CD renewals are even lower on the pecking order. I suggest that the bank in this case verify that its settings are correct. This requirement is old stuff, and established core system providers should have it down pat.