Christmas Club-time deposit product?

Posted By: Trees

Christmas Club-time deposit product? - 05/19/14 04:53 PM

We are changing how our club works. We used to have the booklets, etc. Done with that. We established a deposit account where customers can make deposits but where the customer can't withdraw, deposit over and over again. If they withdraw we close the account. Done.
We are struggling with whether or not this type of account is a savings account and, therefore, where we would be required to send evidence of each deposit, esp. when the deposits are strictly ACHs from the Christmas clubs set up by employers. We do not provide a statement for these accounts.
Thank you.
Posted By: J2C

Re: Christmas Club-time deposit product? - 05/20/14 03:47 PM

You have a requirement to send at least a quarterly statement or more frequent. And, they are subject to Reg. DD. Reg. E if there are electronic transactions.
Posted By: Trees

Re: Christmas Club-time deposit product? - 05/21/14 04:36 PM

They are deposits only. No withdrawals can be made. So, for ACH, we will be sending the evidence of the ACH deposit each time one is made.
For people who make a deposit in person, teller gives the deposit slip.
Based on this, do we still need to provide a periodic statement?

Also, some people have tied their checking account to this account and arranged for ACH deposits. In view of this, do we still have to provide a separate periodic statement for the club account?
Need to settle differences of opinion.
Thanks,
Posted By: BurntSienna

Re: Christmas Club-time deposit product? - 05/22/14 06:22 PM

You're required to send a statement quarterly. If there is an electronic credit, you're required to send the statement monthly.

Whether or not the teller handed the depositor a receipt is irrelevant.
Posted By: Trees

Re: Christmas Club-time deposit product? - 05/22/14 10:08 PM

OK, so we have to deal with this. Funny, when we had the old fashioned coupon books these issues never came up with examiners. We had some people that had the clubs and for which we received ACH credits every week, through employers.