I've not seen Holiday Savings (i.e., Chrismas Club) accounts created as auto-renewable. Typically the customer receives the proceeds and then decides if they want to open an account for the new year. Are others offering auto-renew club accounts and, if so, how are you handling the disclosures that would seem warranted?

When we offered these type of accounts, we would always zero out and close the accounts and issue a check for the proceeds. If the customer wanted to do another year, we re-opened the account and re-issued the disclosures. We no longer offer these (change in management) and no other bank in our area of whom I am aware offers these. We simply offer ordinary savings products and allow them to deposit and withdraw when and how they see fit.

Doug - At my previous bank, we did have automatically renewable Christmas Club accounts. We sent the updated account disclosures with the terms for the next 12 months in the envelope with the checks when they were cut each Nov. 1. This satisfied our examiners.

We do not close our Christmas Club accounts. We issue a check for the balance just like a customer would if they withdrew all the funds in the checking account. If the customer wants to continue, they make a deposit. If they don't make a deposit in about six weeks, the account automatically closes. If they wanted to re-open at some point, we would go through the process and re-disclose.

We also do not close the accounts. Funds are transferred to savings/checking on November 1st. To initially enroll in this type of account, members must sign up for automatic transfers of at least $25/month.

I have a question about PjPs post below.

Doug - At my previous bank, we did have automatically renewable Christmas Club accounts. We sent the updated account disclosures with the terms for the next 12 months in the envelope with the checks when they were cut each Nov. 1. This satisfied our examiners.

Is there a requirement for an updated account disclosure each year?

We send an account disclosure each year with the Club Check, mostly to disclose the current interest rate (even though it's an adjustable rate). We have our Club accounts as Savings not Checking, is everyone sending monthly statements on their Clubs? Or, at least Quarterly if no electronic activity?