Send Reg E Annual Error Notices to CDs?

The conventional wisdom is to send annual Reg E error notices to CDs with interest transfers. However, I note that the definition of account in Reg E would seem to preclude CDs: (1) “Account” means a demand deposit (checking), savings, or other consumer asset account (other than an occasional or incidental credit balance in a credit plan) held directly or indirectly by a financial institution and established primarily for personal, family, or household purposes. 1. Consumer asset account. The term “consumer asset account” includes: i. Club accounts, such as vacation clubs. In many cases, however, these accounts are exempt from the regulation under § 1005.3(c)(5) because all electronic transfers to or from the account have been preauthorized by the consumer and involve another account of the consumer at the same institution. ii. A retail repurchase agreement (repo), which is a loan made to a financial institution by a consumer that is collateralized by government or government-insured securities. 2. Examples of accounts not covered by Regulation E (12 CFR part 1005) include: i. Profit-sharing and pension accounts established under a trust agreement, which are exempt under § 1005.2(b)(2). ii. Escrow accounts, such as those established to ensure payment of items such as real estate taxes, insurance premiums, or completion of repairs or improvements. iii. Accounts for accumulating funds to purchase U.S. savings bonds. Additionally, most CD interest transfers are by check, and Reg E would also seem to exclude a check from an EFT: (c) Exclusions from coverage. The term “electronic fund transfer” does not include: (1) Checks. Any transfer of funds originated by check, draft, or similar paper instrument; or any payment made by check, draft, or similar paper instrument at an electronic terminal. So the question is - do we have to send Reg E annual error notices to CDs, and if so, why?