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#2236194 - 05/05/20 07:24 PM CD investment vehicles-Transaction Limits
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,137
In the mountains
With regards to disclosing transaction limitations on a Truth in Savings disclosure for CDs used as investment vehicles for Traditional/Roth IRAs and Coverdell Education Savings Custodial Accounts, must we disclose the limits applicable to those plans? For example can we say something like:

TRANSACTION LIMITATIONS. You can make additional deposits to this account during a term (except no additions can be made in the 7 day period before any maturity date). Additions will earn interest from the date of deposit and will not change the maturity date of this account. You cannot withdraw principal from this account without our consent except on or after maturity. (For accounts that automatically renew, there is a ten day grace period after each renewal date during which withdrawals are permitted without penalty). Interest accrued during a term can be withdrawn after it is credited to the account balance. Interest earned during one term that is not withdrawn during or immediately after that term is added to principal for the renewal term.
Refer to the Coverdell Education Savings Custodial Account Form 5305-EA and the Coverdell ESA Disclosure Statement for more information.

Or must we be specific and mention the annual dollar limit (subject to phase out for modified adjusted gross income ranges) and that contributions can be made until the Designated Beneficiary has age 18?
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#2236380 - 05/08/20 02:04 PM Re: CD investment vehicles-Transaction Limits Likes to Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 84,360
Galveston, TX
The contribution and distribution limitations are a part of the overall plan. They are not related to a specific CD, as the overall plan may include any number of different investment vehicles. .
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