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#1973225 - 10/30/14 08:22 PM CD IRA - No Maturity Date
CateG Offline
Joined: May 2006
Posts: 60
Based on the IRS reporting limitations of our servicing platform, we are setting up an IRA product as a Certificate of Deposit with no designated maturity date.

Based on this structure and requirements of Reg. D for time deposits, do we have to disclose to the customer that we require they give us a 7 day advanced notice of withdrawal?

If we have to disclose it that way, do we have to enforce the requirement?

Also, based on this structure and requirements of Reg. D, do we have to impose a withdrawal penalty of 7 days' interest on the any amount withdrawn if the withdrawal is made within the first 6 days after deposit?

Does anyone else out structure IRAs as CDs with no maturity date?

Thanks in advance for your help!

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#1973305 - 10/31/14 12:33 AM Re: CD IRA - No Maturity Date CateG
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Not at all certain what you are doing, but if you're going to call this a "time deposit" Regulation DD is going to require you to disclose a maturity date.

(6) Features of time accounts. For time accounts:

(i) Time requirements. The maturity date.

In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1973632 - 11/03/14 03:17 PM Re: CD IRA - No Maturity Date CateG
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
What system are you using? I've used three different platforms from the three big providers and we could set up an IRA savings account on all of them. JHA Silverlake, Fiserv Premier, & FIS Horizon.

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#1973845 - 11/03/14 09:59 PM Re: CD IRA - No Maturity Date CateG
bluesky Offline
Joined: Jul 2005
Posts: 85
We use FIS Horizon and we have an IRA Savings that has no maturity date. Technically it is considered a Time Deposit, but that is only because our platform requires it for proper tax reporting, etc.

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#1974125 - 11/04/14 09:47 PM Re: CD IRA - No Maturity Date CateG
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,036
Cape Cod
A time deposit can have no maturity date if it requires advance notice of withdrawal. We used to call them "time deposit open accounts" and they looked and smelled like savings accounts, but withdrawals had to be preceded by a notice (at the time, it was 90 days, so you can imagine how long ago it was). See 204.2(c)(1)(i)(C).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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