SEP Contribution

Do you know if there is a regulatory prohibition against making contributions to a SEP account during the term of the Certificate of Deposit or is this a decision made by the bank.

Bank decision and something that should be addressed with your ALCO committee. The committee may decide that additional contributions should be made to a new certificate. Remember that the SEP is the umbrella of the retirement plan. There can be as many certificates under that umbrella as you want that make up the assets contributed to the SEP. The money does not all have to be in the same bucket.

Generally, it's irrelevant that the time deposit is held by a SEP/IRA.

Take a look at your TISA disclosure. It must disclose any limitations on a time deposits. In all likelihood, it says no additional deposits are permitted.

Yet, some banks do offer time deposit open accounts (TDOA's). Their disclosures clearly indicate additional deposits are allowed. However, the banks offering TDOA's make a conscious decision to offer the product in the ALCO environment that Brian mentions. They do not do it in "one off" decisions where the proper disclosures are not in place.

Great info Gentlemen....Thanks much.