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#2233102 - 03/17/20 03:02 PM Savings and 7 days advance notice of WD
TeamComply Offline
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Posts: 543
It was mentioned at external training that bank staff recently attended, that on Savings accounts, bank must reserve the right to require a seven-day advance notice of withdrawal, and that this information must be included in the account agreement with the accountholder. Is this typically disclosed in the TISA, account terms and conditions, or someplace else? And is it simply stated something like this: "We reserve the right to require a seven-day advance notice of withdrawal."

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#2233105 - 03/17/20 03:16 PM Re: Savings and 7 days advance notice of WD TeamComply
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Comment 4(b)(5)-1.iii:
Quote
1. General rule. Examples of limitations on the number or dollar amount of deposits or withdrawals that institutions must disclose are:

* * *

iii. Limitations required by Regulation D of the Board of Governors of the Federal Reserve System (12 CFR part 204) on the number of withdrawals permitted from money market deposit accounts by check to third parties each month. Institutions need not disclose reservations of right to require notices for withdrawals from accounts required by federal or state law.


You don't need to disclose it in your TISA disclosures, but it has to be included in the deposit agreement/contract, for savings, NOW and MMD accounts.
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John S. Burnett
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#2233134 - 03/17/20 05:56 PM Re: Savings and 7 days advance notice of WD John Burnett
TeamComply Offline
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Posts: 543
Thank you. And this would apply to business savings, MMDA and NOWs as well?

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#2233141 - 03/17/20 06:08 PM Re: Savings and 7 days advance notice of WD TeamComply
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Yes. Of course, you won't have many business NOW accounts.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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