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#681699 - 02/07/07 03:24 PM CD closed by the Bank within the first six days
comply123 Offline
Member
Joined: Dec 2005
Posts: 76
Hello,

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Deposits and Payments
#681702 - 02/07/07 03:27 PM Re: CD closed by the Bank within the first six days comply123
comply123 Offline
Member
Joined: Dec 2005
Posts: 76
Hello, the Bank decided to terminate the customer relationship and closed the CD within the first six days and did not pose any penalty. How would you have handled this? The customer did not request the withdrawal, we closed it and sent them a check, but is there a violation of Reg D here? Thanks for your input.

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#682262 - 02/07/07 09:38 PM Re: CD closed by the Bank within the first six days comply123
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I suggest that the bank review its procedures and consider delaying any similar transaction to the 7th day from opening.

For this one, I suggest you might consider that the account never truly was opened, particularly if no interest was included in the return of the depositor's funds. At least that's the argument I'd use if challenged by an examiner.
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