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Regs/Requirements for Time Deposit Accounts

Question: 
Our company is wanting to offer Time Deposit accounts. I have read Reg. DD and I see that Time Deposits have certain restrictions on withdrawal periods and penalties but I don't think they are much different than Certificate of Deposits and Auto Save IRA CD's. Basically if we adhere to TISA requirements are we okay to offer these or should I be looking into any other regs or requirements?
Answer: 

by Randy Carey:

A certificate of deposit is a form of a time deposit. I am unsure of what sort of time deposit you may be referring too?

204.2(c)(1) Time deposit means:

(i) A deposit that the depositor does not have a right and is not permitted to make withdrawals from within six days after the date of deposit unless the deposit is subject to an early withdrawal penalty of at least seven days' simple interest on amounts withdrawn within the first six days after deposit.

Answer: 

by Richard Insley:

Randy - Sounds like what we used to call a TDOA (time deposit open account.) Although it looks like that term bit the dust years ago, the concept still fits within the definition you cited.

First published on 02/17/2019

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