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#1924399 - 05/19/14 04:53 PM Christmas Club-time deposit product?
Trees Offline
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Joined: Apr 2005
Posts: 4,013
We are changing how our club works. We used to have the booklets, etc. Done with that. We established a deposit account where customers can make deposits but where the customer can't withdraw, deposit over and over again. If they withdraw we close the account. Done.
We are struggling with whether or not this type of account is a savings account and, therefore, where we would be required to send evidence of each deposit, esp. when the deposits are strictly ACHs from the Christmas clubs set up by employers. We do not provide a statement for these accounts.
Thank you.

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#1924741 - 05/20/14 03:47 PM Re: Christmas Club-time deposit product? Trees
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
You have a requirement to send at least a quarterly statement or more frequent. And, they are subject to Reg. DD. Reg. E if there are electronic transactions.
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My opinion is mine only- not my employer's!


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#1925210 - 05/21/14 04:36 PM Re: Christmas Club-time deposit product? Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
They are deposits only. No withdrawals can be made. So, for ACH, we will be sending the evidence of the ACH deposit each time one is made.
For people who make a deposit in person, teller gives the deposit slip.
Based on this, do we still need to provide a periodic statement?

Also, some people have tied their checking account to this account and arranged for ACH deposits. In view of this, do we still have to provide a separate periodic statement for the club account?
Need to settle differences of opinion.
Thanks,

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#1925784 - 05/22/14 06:22 PM Re: Christmas Club-time deposit product? Trees
BurntSienna Offline
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Joined: Aug 2006
Posts: 2,407
Midwest
You're required to send a statement quarterly. If there is an electronic credit, you're required to send the statement monthly.

Whether or not the teller handed the depositor a receipt is irrelevant.
_________________________
"Gratitude makes sense of our past, brings peace for today, and creates a vision for tomorrow." - Melody Beattie

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#1926005 - 05/22/14 10:08 PM Re: Christmas Club-time deposit product? Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
OK, so we have to deal with this. Funny, when we had the old fashioned coupon books these issues never came up with examiners. We had some people that had the clubs and for which we received ACH credits every week, through employers.

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