After numerous discussions with management, I could use some outside help. Here is how our holiday/vacation club accounts are structured: Specific maturity date (can be opened any time up to that date so term varies), automatically renewable unless the customer notifies us, customer does not have the right to make withdrawals before maturity without forfeiting all accrued interest and they are assessed a service charge of $25. While we do not refer to it as an "early withdrawal penalty" calculated in terms of at least seven days interest, doesn't our approach have the same impact on the customer? (1% interest for seven days, on an opening deposit of $10,000 is less than $2, and $25 is greater than this) I am leaning towards these accounts being classified as time accounts. If we allow withdrawals during the first six days after opening without a penalty, we should be OK classifying them as savings deposits. Any opinions would be appreciated?

Time

Would we need to send prematurity notices for automatically renewable time accounts to everyone with one of these accounts? Going forward, I think the accounts are going to be restructured so they are no longer time accounts, thus relieving us from associated disclosures.