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#402931 - 08/12/05 08:52 PM Reg. D - Early Withdrawal Penalties
Anonymous
Unregistered

Am I correct that the only regulatory requirement on an early withdrawal of a time deposit is the "loss of seven days interest on funds withdrawn within the first six days of deposit or withdrawn within six days of a previous partial withdrawal."

Has the old regulatory penalty for "nonpersonal time deposit accounts" with maturities of one and one half years or more disappeared? I can't seem to find it in Reg. D.

Thanks.

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#402932 - 08/12/05 08:56 PM Re: Reg. D - Early Withdrawal Penalties
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
It's gone. Consigned to the scrapheap of history.
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#402933 - 08/12/05 09:02 PM Re: Reg. D - Early Withdrawal Penalties
Anonymous
Unregistered

Thanks for the prompt reply. Is the only penalty the one I mentioned in the first sentence?

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#402934 - 08/12/05 09:19 PM Re: Reg. D - Early Withdrawal Penalties
David Dickinson Online
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Quote:

Thanks for the prompt reply. Is the only penalty the one I mentioned in the first sentence?



Yep. That's it.
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http://www.bankerscompliance.com

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#402935 - 08/12/05 09:21 PM Re: Reg. D - Early Withdrawal Penalties
Anonymous
Unregistered

Yippie! I can go home now. Thanks again.

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#1749118 - 10/12/12 10:09 PM Re: Reg. D - Early Withdrawal Penalties Anonymous
NHBankGuy Offline
Junior Member
NHBankGuy
Joined: Jan 2002
Posts: 35
Manchester, NH
Sorry to resurrect this post, but the OCC exam manual still references the penalty on 18 month nonpersonal CDs. From page 5 of the Depository Services booklet of the Comptroller's Handbook:

"NOTE: For reporting purposes only, other time deposits are normally classified as short-term deposits. If the deposit has a maturity of 18 months or more and one month’s simple interest early withdrawal penalty is imposed for withdrawals made between day seven and the end of month 18, instead of the normal seven days penalty, the deposit may be classified as a long-term deposit."

It looks like this requirement went by the wayside when the FRB changed the reserve rate on nonpersonal time deposits to 0. I would just like to find something from the FRB or another regulator that confirms that. Any ideas?
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#1749122 - 10/12/12 10:38 PM Re: Reg. D - Early Withdrawal Penalties Anonymous
NHBankGuy Offline
Junior Member
NHBankGuy
Joined: Jan 2002
Posts: 35
Manchester, NH
Never mind - found it! 61 CFR 69020 (12/31/96) is the notice repealing the requirement. Strange that the OCC still has it in their Comptroller's Handbook 16 years after its repeal!

Have a great weekend...
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Opinions are not necessarily those of my employer and should not be construed as legal advice.

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