We currently offer IRA's to our customers. The funds are deposited into Certificate of Deposits. My question is: Should we have separate TIS disclosures for our IRA accounts or would they simply fall under our TIS disclosures for Certificate of Deposits?

Thanks

Our IRAs are backed by only one product, a CD, and that CD # is referenced in the IRA documents that the customer receives. The TIS disclosures relate to the CD.

We only offer one type of product also, a CD, but there are a few differences between a regular CD and an IRA CD. One being that we do not charge a penalty to a customer doing a distribution from their IRA if they are over 59 1/2. We have chosen not to do this because they are not penalized by the IRS - even if the CD is not mature. We do however charge a penalty if they transfer the whole amount to another institution before it is mature. We also charge a $50 transfer fee.... None of this is disclosed in the TIS disclosure for regular CD's.....which got me to thinking that we may need separate forms.

Separate forms is up to you. They are definite products that need to be disclosed differently.

Thanks! That's what I was thinking......