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