Answer:
You have to comply with the renewal notices provisions of Regulation DD anyhow. If the CD in question has an initial term of more than a year, you have to include a full Reg DD disclosure that addresses the early withdrawal penalty provision. If it's for one year or less, you send either a full disclosure or a limited one that includes the information that will change on renewal.
As a practical matter, getting the information a few days before renewal is probably more helpful to your depositor than getting it 6 months earlier.
First published on BankersOnline.com 6/11/12
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