I think you are interpreting it correctly, Linda. If the problem arises, you probably should delay the ability of the customer to access the CD until the week has past since the last deposit.
That said, if one of these slips through your controls, you shouldn't panic. Just check out the controls you have in place and try to prevent the scenario you've described.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8