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#2269774 - 04/28/22 03:49 PM IRA CDs - Error found for minimum balance
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,082
In the mountains
I just determined that we are paying interest on IRA CDs no matter the balance. So even though there is a minimum balance to open the account, if the balance goes below that amount, we still pay interest. Unfortunately the IRA CD TIS says that the account must have a minimum balance of $100 to earn interest. Thankfully, we haven't harmed the customer since we are paying on balances below that. However, do we need to redisclose a TIS to any customer who received a TIS with the incorrect wording?
Always learning something new...

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Operations Compliance
#2270035 - 05/04/22 04:33 PM Re: IRA CDs - Error found for minimum balance Likes to Comply
burkemi Offline
Platinum Poster
Joined: Nov 2013
Posts: 541
You mean you'll continue to pay interest below $100? If so, you could do a courtesy notification.

You mean you're going to stop paying interest below $100? If so, a notice should absolutely be sent since you will be discontinuing an established practice.
I reject your reality and replace it with my own.

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