The CD contract will include an early withdrawal penalty provision. That penalty must be at least as great as the penalty required by the regulation. With interest rates trending slowly upward, you will want to have a penalty provision that doesn't make it easy for a customer to "trade" a very low rate CD for one carrying a higher rate.
In your disclosures, you will state that there is a penalty for early withdrawal and how it is to be calculated. For example you could say that there will be a penalty of 30 days' interest at the rate on the CD for any full or partial early withdrawal (if that's what the contract calls for).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8