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Latest Operations - Certificate of Deposit Topics

Disclosing Actual CD Penalties

04/16/2023

What is required on a CD Partial/Early Redemption Form? The penalty we assess on CD withdrawals has been disclosed on the CD disclosures given in accordance with TISA. When a customer requests a partial/early redemption, most deposit documentation systems will generate a form for the customer to sign. In relation to the form, are we required to disclose the amount of the penalty that will be assessed? For example: A customer withdraws $10,000 and the penalty is $100. Is it acceptable for the partial redemption form to only disclose the gross withdrawal amount of $10,000? - Or - Are we required to show full itemization of the gross amount, less the penalty, and the net amount paid to the customer ( In my example, $10,000, less a penalty of $100, yields a net of $9,900 to be distributed?

CD Redemption Fees

12/04/2022

We recently had a CD held by a Revocable Trust where the Grantor/Co-Trustee died. The other trustee came in and asked to redeem the CD early due to death. We waived the early redemption penalty due to death, but asked ourselves, is this a regulatory requirement or a courtesy, particularly in this case because a Trust doesn't "die".

Irrevocable Burial Trust Accounts Opened As CDs

01/06/2019

I have some questions regarding irrevocable burial trust accounts opened as Certificate of Deposits. Should the original CD be given to the account owner? Should the renewal notices go to the account owner or the funeral home?

New Beneficiary Names Due to Death

09/30/2018

Best practice for closing and reopening IRA and or ​CD accounts in new beneficiary names due to death. Should we keep the same rate or give the current rate which is less?

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HMDA/Section 1071 Question

12/08/2024

I have a question about a SBDC exclusion. I know that the exclusions reference that HMDA reportable transactions are excluded. We are a non HMDA bank so what we initially thought based on the prior SBDC trainings I have been to and the research that we have done is that we would exclude transactions that would be HMDA reportable if we were a HMDA reportable bank. However, I recently went to a Forvis compliance conference and what I heard there caused some confusion for me in regards to that. We are a non HMDA bank due to us not having a branch in an MSA and not because of our loan volume. So their interpretation was that HMDA transactions would not be excluded for us since we don’t have a bank in an MSA and since our loan volume wouldn’t exclude us from HMDA if we were in an MSA. I can see following the citations how they derived to that answer but this is the first time I had heard it interpreted that way. Can you give any guidance or clarification on this?”

Reg E and mobile payments

12/01/2024

Our customer received a call telling them their CashApp account was compromised, and they needed to verify the password. After they did this there were several authorized CashApp transactions. Can we tell the customer they have to resolve the issue with CashApp?

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