We are going to start charging our customers an IRA disbursement fee (taking their IRA elsewhere). I understand that we will need to send this letter 30 days before the change. However, can we also explain in our letter other options or alternative IRA programs that we offer?

You're assuming that Regulation DD is your only concern when you are imposing a charge on IRA participants?

The penalty you are considering isn't on the time deposits the IRA holds, it's on the action the participant is taking; i.e. he's not just taking the funds out, he's taking them to another bank. You need to get some advice from an attorney who can tell you what the acronym "ERISA" stands for before you begin the conversation.

Okay started briefly reading up on ERISA and feeling a little 'in over my head'. Are we allowed to charge our customers for transferring or rolling over our IRA to another organization?