Are CDs subject to Reg E? I would consider them a "consumer asset account", however unless we allow electronic transfers I don't think they would be covered. Can someone confirm that for me? Thanks!

I agree with you. I have never heard of a CD having EFT activity.

A CD can have EFT activity if the interest is being transferred to a different account. While this in not common, it does happen.

You're right and I stand corrected.

You might want to review this post:

Here

Of course, I hate to bring this up again

And, since Randy turned over this rock yet another time (he's a glutton for punishment!), you'll also want to make note of the new Interpretation to Reg. E, section 205.10(d)(2):

2. Transfers to an account of the consumer held at another institution. A financial institution need not provide a consumer the option of receiving notice with each varying transfer, and may instead provide notice only when a debit to an account of the consumer falls outside a specified range or differs by more than a specified amount from the most recent transfer, if the funds are transferred and credited to an account of the consumer held at another financial institution. The specified range or amount, however, must be one that reasonably could be anticipated by the consumer, and the institution must notify the consumer of the range or amount at the time the consumer provides authorization for the preauthorized transfers. For example, if the transfer is for payment of interest for a fixed-rate certificate of deposit account, an appropriate range might be based on a month containing 28 days and a month containing 31 days.

Although that language doesn't mention statements, it certainly clears up the question of whether a CD can be subject to Reg. E. If it is, then the statement requirements of § 205.9(b) will also apply.

If your bank permits "out of bank" transfers of interest on CD accounts, and the interest varies with the number of days in the month, you'll want to adapt your customer authorization form for EFT of interest to indicate something like "The amount to be transferred will vary monthly, in a range estimated to be from $______ (interest for 28 days) to $_____(interest for 31 days).

If your processing system allows the interest period on CD accounts to vary outside the range of 28-31 days (due to non-processing days, for example), adjust the suggested wording accordingly.