Help- Retail compliance was recently dumped on me- I am a loan girl- anyway-We currently use a manual process- I hate manual processes- whereas we have CD maturity notices kicked out of the server system and sent to the main branch and then our CSR puts a new account disclosure in the envelope with the CD Maturity notice. Is it me? but if we were much larger the process would be labor intensive and why do we do this anyway? Looking at Reg. DD I see under (C)(1)Existing Account Holders: The notice shall state that consumers may request account disclosures containing terms, fees, and rate information for their account. In responding to such a request, institutions shall provide disclosures in accordance with paragraph (a)(2) of this section.

Am I missing something or is the actual disclosure needed at time of CD maturity or is it only required that the notice say "call us if you want the disclosures again?"

Not sure, but you may want to read 230.5(b) - subsequent disclosures for CDs. Depends on maturity period and autorenwal or not.

You need to look at section 230.5 of Reg DD. Reg DD section 230.5

Looked at that too and it referred back to 230.4(b)

1) Advance notice required. A depository institution shall give advance notice to affected consumers of any change in a term required to be disclosed under Sec. 230.4(b)

Looking at 230.4(b) -so all that is included in the New Account Disclosure and it must be sent for terms over 1 year- thanks- I think the muck is a little clearer- just seems like overkill.

Most core processors produce a CD notice that complies with the disclosure requirements without "stuffing" a disclosure in the envelope. Somethin' ain't right here.

Consumer protection regulation...

Depending on how the CD was established/opened, a customer may forget the terms/conditions/etc. after more than one year, especially a 5 yr CD.

And possibly different features in the CD products offerings at the bank.

Just my opinion.

Thanks first anon- I agree- something is not right here. When looking at the maturity notice I see the following:
Maturity date
Interest rate and APY not yet set statement
Available rate date
# to call
date of notice
Balance
current rate

According to DD for CD's over 1 year I need to add all of the "stuff" in 230(b? Where? The notice is 3.5" X 8.5". We are a FiServ Vision Bank- anyone know what I should do to fix this?

You do what most banks do -- create an insert that includes all of the other New CD disclosures and you stuff it with the Fiserv notice. Contrary to an earlier post, I don't believe that most systems create a full and adequate disclosure in the impending maturity notice for CDs with terms over 1 year.

From Reg. DD: "(1) Maturities of longer than one year. If the maturity is longer than one year, the institution shall provide account disclosures set forth in Sec. 230.4(b) of this part for the new account, along with the date the existing account matures. If the interest rate and annual percentage yield that will be paid for the new account are unknown when disclosures are provided, the institution shall state that those rates have not yet been determined, the date when they will be determined, and a telephone number consumers may call to obtain the interest rate and the annual percentage yield that will be paid for the new account."

For CDs over a year, most community banks I know of use a pre-printed notice from the computer with the additional information required by the second sentence above, supplemented by the initial disclosure the bank gives at account-opening as a separate insert to cover the information required by the first sentence above.

So murphysgirl, the way your bank is doing it is the same way I've seen many other smaller community banks do it for CDs over 1 year.

I don't know if there is a more efficient or more cost-effective way to do it, but the way you are describing is compliant with the reg.

thanks everyone- I was really hoping for an easier way-

Before we had the ability on JHA to customize an 8-1/2 x 11 notice, we added a few fields to our smaller computer-generated CD maturity notice (i.e., interest payment method and interest payment term) and mailed with a generic CD disclosure that contained the full disclosure. We had to develop 3 different generic notices (fixed-rate CD, floating rate CD and IRA).