Certificate of Deposit
02/18/2024
I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date.Here is an example: a CD term is 6 months and interest is paid every 30 days.Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?
CD Renewal Rate Disclosures
02/11/2024
I have a question about a CD special. The bank's rate sheet lists a 12-month CD as well as a 12-month CD Special that has a considerably higher interest rate/APY than the regular base CD. The bank also allows negotiation and will pay a higher rate to keep business. For the "special" and any other negotiated rate, the rate is only in effect for the initial term and at maturity will renew at the 12-month non-special rate.I'm looking at 1030.5; Comment 5(a)(1)-1 and I am thinking that advance notice would be required since the terms are changing upon the occurrence of an event (renewal). There is nothing on the TIS disclosing that the initial term is a promotional period and that the CD will renew at the lower non-special rate in effect.Am I thinking about this correctly?
Specificity of CD Beneficiary
03/05/2023
For a Certificate of Deposit account, can the beneficiary on the account be titled as "Assigns'" in lieu of a specific named beneficiary?
Adding Owners CDs
01/29/2023
We have a CD that the customer wants to add a joint owner to in mid-term of the CD. I am thinking we should issue in lieu of since we are technically changing ownership. Others think we should just re-write the CD adding the joint owner while keeping everything else the same. What is your recommendation and why?
Garnishment of CD Pledged to Loan
09/25/2022
We have a certificate of deposit pledged to a loan. The CD amount exceeds the loan balance by a couple thousand dollars but the original hold was even greater as the loan originated at 60% of its original amount. We recieved a garnishment which will include this CD.Are we obligated to decrease the hold amount to the balance of the loan on the date of receipt of the garnishment and send the excess funds to the court or does the full amount of our original hold superceed this, meaning we would report there are no funds available? I am in Oklahoma if it is a state law issue.
CD penalties and waiving them
09/18/2022
Can we waive a CD penalty?
Truth in Savings on business accounts? Not required.
09/11/2022
Do we give out Regulation DD disclosures on business accounts?
Reg DD-Advertising a CD Special on Rate Sheet
11/10/2019
When advertising a CD special on a rate sheet that will be provided to customers, and the ad only indicates the CD special product name with astatement that says, "ask us how to open your CD special," and nothing else, but the CD special has conditions and limitations that the regular CDaccounts do not, should a bank disclose on the rate sheet what those conditions and limits are that differ from the regular CD products that arealso listed on the rate sheet?There is a fully disclosed addendum for the special that covers the Reg DDdisclosure requirements. However, this will only be provided if the specialis opened by the customer. My concern is that if the customer only requeststhe rate sheet and doesn't open the account the customer will not receivethe addendum or the full scope of the special on the rate sheet and this maybe a little misleading if the customer comes back at a later date to openthe special and they find out there are conditions to be met on the product.
CD Product with All Interest Paid Up Front
08/25/2019
Our bank is exploring the idea of a new CD product in which all the interest is paid up front on the date of initial deposit. In the case of earlywithdrawal, are we able to deduct the penalty from the principal since there would be no interest accruing during the CD term?
Regs/Rules on Opening CDARS Accounts
06/30/2019
When opening a CDARS account, are the following required:1. Customer signature on signature card2. Legal/organizational documents on commercial entity3. Beneficial Ownership formsCan you also give me info on where to locate the laws and regulations governing the opening of the CDARS accounts?
