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TISA Disclosure for CD Business Customers

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Question: 
On our old operating system we provided a TISA disclosure to our business customers when they opened a certificate of deposit (CD). Our new operating system separates personal accounts from non-personal accounts and does not automatically produce this disclosure for a business customer. Only a CD receipt is generated for non-personal. It lacks interest calculation and detailed penalty information. The two products function identically. By providing our business customer with the TISA disclosure we are ensuring that they receive detailed interest calculation and penalty information. We think it's important for them to receive this information to avoid UDAAP concerns. Rather than reinventing the wheel, it seems simpler to give them a TISA disclosure. Do you see a problem with providing a TISA to our CD business customers?
Answer: 

As long as it is accurate, there would be no harm.

First published on 08/18/2019

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