CD Pre-Maturity Notices and Disclosures

Posted By: Kelsey D

CD Pre-Maturity Notices and Disclosures - 08/15/13 03:46 PM

I think our process is very similar to most banks when it comes to renewing CDs. Our core system generates an approaching renewal notice that includes the current and new maturity dates. We mail the notice along with a one-page stuffer that has the full TIS disclosures. I'd like to avoid having to fill in anything on the disclosure. So...

1) Where we state that the rate and APY will be available on [date], can I just refer to the current maturity date on the renewal notice instead of typing in the date?

2) Where we state that the new certificate will mature on [date], can I just refer to the new maturity date on the renewal notice instead of typing in the date?

Nothing else on the disclosure is account specific, so referring to the renewal notice will eliminate customization.

Thoughts?
Posted By: John Burnett

Re: CD Pre-Maturity Notices and Disclosures - 08/15/13 04:14 PM

The impending maturity notice and the stuffer together constitute the notice required by the regulation. I see nothing wrong with referring to the other document in the mailing. What you can't do is refer to the new maturity date in a manner like "24 months from the current maturity date." You have to cite the specific date within the mailing.
Posted By: Kelsey D

Re: CD Pre-Maturity Notices and Disclosures - 08/15/13 04:25 PM

Thank you, John! Happy Birthday!