Looking for any suggestions on stopping renewable CODs for businesses. More importantly, what to do with those that will be maturing and are eligible for renewal? This all has to do with the banks plan for Certification and Re-certification for Beneficial Ownership. Our disclosures state we can close the COD for any reason, but it seems to me we would want to notify them of the fact that we are calling (is that the term for this?) their COD and not renewing the existing COD and why. I've never had to deal with this type of thing before and looking for your input.

As Regulation DD does not apply to non consumer accounts, your disclosures must be of your own design and it's hard to imagine what they might say. (It is highly doubtful that you have the right to "call" or terminate the contract unilaterally.) If the regulation did apply, you would notify the customer of the change in terms, elimination of the the automatically renewable feature, in the maturity notice which is generally sent 10 days prior to maturity. Barring contractual language to the contrary, that should work.

Figure out now how many customers (time deposits) this actually applies to. Put every other aspect of your beneficial ownership program in place first and worry about this when everything else is done. It's possible that FinCEN may interpret the issue out of existence. Either way, it's not that big of a deal.

Ken - Thank you for your help