Our new core system offers both notices for CDs.

The advance notice states your account will mature and renew on date. And the interest rate and annual percentage yield have not yet been determined, but will be available on date....

and

The Renewal Notice states your CD has renewed wtih a new rate of x.xx% and a new annual percentage yield of x.xx%...

So my questions are:

1) On CDs are we required to provide both notices or is the advance notice alone sufficient - if it is provided 20 calendar days prior and a 10 day grace period is given.

2) Should a similar renewal notice be given on IRAs?

1030.5(b)(1) & (2) require notice prior to maturity for time deposits with maturities of greater than one month provided 20 calendar days prior to the end of the grace period.

Remember that 1030.5(b)(2) requires all of the required time disclosures be provided for time deposits with maturities greater than one year. Many system generated renewal notices are missing information about penalties, minimum deposits to open/earn APY, etc.

1030.5(c) requires notice 10 calendar days prior to maturity for non-renewable time deposits.

There is no requirement to provide an additional notice at or after maturity.

If your IRA products meet the definition of a time deposit, then these requirements are equally applicable to those accounts, too.