We recently merged with another financial institution and their certificates of deposit are single maturity and don't earn interest after the maturity date. I'm trying to determine what the notification requirements are for these types of CD's. I see in the regulation the requirement if the term is over 1 year, but am unable to locate anything about terms under 1 year. Is anyone familiar with this?

Thank you!

There are disclosure requirements for non renewable time deposits when they are sold, but none when they mature.

Upon maturity, these contracts become non interest bearing demand deposits. Sending a maturity notice would be a fundamental courtesy, but its content would not be affected by the instrument's original term.

Thank you Elwood.

I've never worked at a financial institution that had non-renewable certificates before so I was a little confused and couldn't find what I was looking for - because it's not there. I'll pass this along and include the Reg DD requirement for certificates with maturities greater than 1 year.

As Harvey's pal, Elwood, said earlier, there simply are no maturity notice requirements for non-renewing time deposits with terms of under one year. The deposits you describe simply become non-interest-bearing demand deposits (by definition in Regulation D -- 12 CFR part 204 -- and by contract).

When Regulation DD was first proposed, I worked with a group at the ABA that drafted a response to the Federal Reserve's proposal. Our recommendation, adopted by the Fed, said that there need not be a maturity notice under the regulation for these short-term accounts, since the depositors should have a memory or record of the impending maturity date.

So, unless state law compels you to send a maturity notice, you don't have to (my more seasoned view now agrees with Elwood's that a maturity notice would nonetheless be a courtesy, and I recommend it). Because there's no renewal anticipated in the deposit contract, it makes no sense to include disclosures that would be required if the account automatically renews. You could include with that optional maturity notice a rate card (compliant with the advertising rules for time deposits and with the Member FDIC statement, of course) for your current CD offerings in case the customer wants to reinvest the funds.