Does anyone know of an exception to Reg DD for Christmas Club Savings Accounts? A competitor bank offers this account but no bank disclosures are given to the customer. We're developing this new product for our bank and any advice would be appreciated.

I'm not aware of any exemptions for Christmas Club accounts. I haven't seen one of those in years - do banks really still offer these? We ran a cost/benefit on them in the late 80's and 86ed them way back then.

Also some banks don't pay interest. If that is the case there would be no TIS disclosures.

We still offer them - I love mine! We also provide a Truth in Savings Disclosure. They are not exempt that I'm aware of.

We offer them as well. I believe they are not exempt from Reg DD. We, however, state in our disclosure that we restrict any withdrawls from these accounts except for the annual payout.

It's not a money maker but customers love the account. Our original Christmas Club was eliminated for the same reasons as yours, but customer demand has brought it back. Thanks for the info.

All consumer accounts are subject to Reg DD TISA requirements, even if they don't pay interest.

We have both a Christmas Club (winter) and a Vacation Club (summer)accounts. Expensive way to get a small amount of deposits. As a consumer, I like it. My paws can't get hold of the money.

Our bank " tried" eliminating them back in the early 90's but this is a great product for the average consumer. No, it's definately not a money maker for the bank but as a small community bank, it fits our image. Yes, we give a TIS and all required disclosures.
To be politically correct , we renamed it from a Christmas Club to a Wish Club and the customer chooses their own maturity date (minimum six months).

We offer them as well and they are quite popular. If you would like a copy of our disclosure, e-mail me at san@the1st.com and I will send you one. They are definitely not exempt.

Opinions are mine and mine alone.

We offer Christmas Club accounts and cut a check every October. Because they have a maturity date Maryland law requires we pay 3.00% interest. Needless to say we are looking at other alternatives for next year's club accounts.

We offer them, and my opinion is that they require Reg DD disclosures. On what basis would they not be subject? Just curious as to the details of your product.

Teresa,
Maryland only mandates the 3.00% rate if your account has a term of 1 year or less. If you distribute the funds in October but the account remains open, this section would not apply.

Do you also give them an EFT disclosure? If the only transfer capability is for the customer to transfer money from a checking to the christmas club account or vice versa would the club account be exempt?