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 D, do we have to impose a withdrawal penalty of 7 days' interest on the any amount withdrawn if the withdrawal is made within the first 6 days after deposit?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!

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.

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.

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.

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).