We are currently in the process of creating an IRA Savings account for our customers. In the past, we have only offered CD's for an IRA. My question is: Do we need to send monthly/quarterly statements for the IRA Savings accounts? I know on regular savings accounts we have to send a statement if there are electronic transfers made and the only time I can think we may have an electronic transfer to/from our IRA Savings would be if there is a direct deposit. I do not believe we are allowing electronic withdraws. I wasn't sure though, if an IRA account fell under the same rules as a regular savings account? If we do have to provide a statement, what information would be required? We currently open an IRA Plan which then could have multiple CD's and now a savings account within the Plan. Would we have to show the total IRA Plan balance or just the IRA Savings balance?

Thanks in advance!

An IRA savings account is covered under Reg. DD, so all Reg. DD disclosure and requirements have to be met. However, an IRA savings account is not covered under Reg. E.

Paragraph 2(b)(2)

2. Custodial agreements. An account held under a custodial agreement that qualifies as a trust under the Internal Revenue Code, such as an individual retirement account, is considered to be held under a trust agreement for purposes of Regulation E.

Thank you Randy!

One more question if I may.....

We are planning on not allowing preauthorized transfers on our IRA savings account, except for direct deposit to the IRA savings account. Customer will be required to come into the bank for all withdraws and transfers so the proper paperwork can be signed. Since preauthorized transfers will not be allowed, do we need to disclose the Reg D limit on preauthorized transfers? I planned on simply disclosing that the customer would have to come into the bank for withdraws and transfers to sign necessary paperwork. Online banking functions will be "view only" also.

Sorry to be such a pain! Thanks again!!

I think I answered my own question......

We will allow preauthorized transactions for RMDs (monthly, bi-weekly etc), so in my opinion we leave the Reg D disclosure alone. I don't know if there is a way to not allow ACH debit transactions or not - I will have to check with our IT department on this.

I may be making this harder than I should - but I feel like one question leads to 10 more......