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#2236068 - 05/01/20 06:59 PM IRA / CDs - Callable time accounts
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Joined: Nov 2008
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In the mountains
1030.4(b)(6)(i) - 1. “Callable” time accounts. In addition to the maturity date, an institution must state the date or the circumstances under which it may redeem a time account at the institution's option (a “callable” time account).

I came a across an IRA CD that was marked as callable when notification is given in writing. That explanation does not seem to meet the requirement above.

So my question is, what are circumstances that an FI would call a time account? Is there any specific reason this option would be needed for IRAs where a CD is the investment tool?
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#2236070 - 05/01/20 07:16 PM Re: IRA / CDs - Callable time accounts Likes to Comply
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rlcarey
Joined: Jul 2001
Posts: 79,958
Galveston, TX
What is your question? Do you have to disclose a call provision in your TISA disclosure or why would you offer a callable CD?
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#2236073 - 05/01/20 07:53 PM Re: IRA / CDs - Callable time accounts Likes to Comply
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I guess if a FI wants the CD to be callable, what is the proper way to disclose it. Is it enough to just say it is callable upon notification by us? must we disclose that it is callable in specific circumstances and list those circumstances? or must we include a time period, such as after 6 months we can call the CD at our option?
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#2236074 - 05/01/20 08:07 PM Re: IRA / CDs - Callable time accounts Likes to Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,958
Galveston, TX
There is no model language. If you can call the time deposit at any time at your discretion, you just need to make that statement.

I have not seen a consumer callable time deposit in a very very long time.
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