Pre-Maturity Notices for CDs

Posted By: ACBbank

Pre-Maturity Notices for CDs - 07/20/21 04:18 PM

Is it required to include Pre-Maturity Notices in our TISA Disclosures?
Posted By: BrianC

Re: Pre-Maturity Notices for CDs - 07/20/21 04:32 PM

I'm not sure I understand your question. You have to provide certificate of deposit maturity notices prior to maturity depending on the length of the term as noted in 1030.5.

These notices reference back to 1030.4 to tell you what information they must contain, but they are completely separate from the disclosure given at account opening.
Posted By: ACBbank

Re: Pre-Maturity Notices for CDs - 07/20/21 04:45 PM

That's my understanding as well Brian. However, we have a vendor insisting this information needs to be disclosed at account opening and included with our account opening disclosures.
Posted By: rlcarey

Re: Pre-Maturity Notices for CDs - 07/20/21 05:04 PM

" However, we have a vendor insisting this information needs to be disclosed at account opening and included with our account opening disclosures."

What specifically are they referring to when they say "this information"?
Posted By: BrianC

Re: Pre-Maturity Notices for CDs - 07/20/21 07:10 PM

1030.4(b)(6) requires information about maturity and whether or not the certificate is auto-renewable. This doesn't take the place of the maturity notice of 1030.5. To echo Randy, is you vendor wanting to put more on the disclosure than what is noted below?

(6) Features of time accounts. For time accounts:

(i) Time requirements. The maturity date.

(ii) Early withdrawal penalties. A statement that a penalty will or may be imposed for early withdrawal, how it is calculated, and the conditions for its assessment.

(iii) Withdrawal of interest prior to maturity. If compounding occurs during the term and interest may be withdrawn prior to maturity, a statement that the annual percentage yield assumes interest remains on deposit until maturity and that a withdrawal will reduce earnings. For accounts with a stated maturity greater than one year that do not compound interest on an annual or more frequent basis, that require interest payouts at least annually, and that disclose an APY determined in accordance with section E of Appendix A of this part, a statement that interest cannot remain on deposit and that payout of interest is mandatory.

(iv) Renewal policies. A statement of whether or not the account will renew automatically at maturity. If it will, a statement of whether or not a grace period will be provided and, if so, the length of that period must be stated. If the account will not renew automatically, a statement of whether interest will be paid after maturity if the consumer does not renew the account must be stated.
Posted By: ACBbank

Re: Pre-Maturity Notices for CDs - 07/20/21 08:40 PM

The vendor is saying we need to include the pre maturity text in the initial disclosure. We have auto renew CDs and include the maturity date and grade period (10) calendar days. The want the below text included as well:


"The interest rate for the renewed account will be ----% with an annual percentage yield of ----%; or

The interest rate and annual percentage yield have not yet been determined. They will be available on (date). Please call (phone number) to learn the interest rate and annual percentage yield for your new account."
Posted By: BrianC

Re: Pre-Maturity Notices for CDs - 07/20/21 08:47 PM

No. That language does not belong on the initial disclosure.
Posted By: ACBbank

Re: Pre-Maturity Notices for CDs - 07/20/21 08:52 PM

That's what I thought as well. Thank you Brian/Randy.