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#2203016 - 01/15/19 04:48 PM Certificate of Deposit and addtional disclosures
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
Do we have to provide any additional disclosures that are not already on the "CD Copy and CD Signature Card"? We use the Wolters Kluwer CD form that has the "Additional Terms and Disclosures" section on the bottom half of p.1 and all of p.2--definitions, transfer, pledges, types of ownership, set-off, balance computation, etc.

We've also been providing the W-K Terms and Conditions (10 pages) for our state, Expedited Funds Availability Disclosure, and Privacy Disclosure.

Yes, we need to provide the Privacy Disclosure.

I think the multi-page Terms and Conditions is redundant and the Expedited Funds Availability is not necessary/applicable.

Please advise. Thanks.

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Deposits and Payments
#2203225 - 01/16/19 10:24 PM Re: Certificate of Deposit and addtional disclosures crc
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
Advice, anyone? Thanks.

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#2203229 - 01/16/19 10:38 PM Re: Certificate of Deposit and addtional disclosures crc
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,712
Illinois
Hard to answer since I cannot say whether or not the form you have in front of you satisfies all of the Truth-in-Savings disclosure requirements for time accounts. Your terms and conditions document may have required legal disclosures for your state so I cannot opine on whether or not this document can be excluded. Legal counsel should review this document to determine if it is needed.

Reg CC only applies to transaction accounts unless your state law extends Reg CC requirements to savings or time accounts or your bank's Reg CC Policy is extended to savings or time accounts. Again I cannot opine because I am not reviewing your bank's documents and since I am not an attorney I cannot opine on state law.
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