Our vendor-provided pre-maturity notices for time deposits with maturities greater than 1 year do not include all the stuff required by Reg. DD. Do most vendor's notices meet the requirements of the Reg.?

Thanks!

W

Normally, it's just a duplicate of your normal TIS disclosure, or a custom one that contains all of the (b) elements.

Do most vendor's notices meet the requirements of the Reg.?

No

Why do you think that is?

Too many variablies. - Late charge penalties, etc.

Late charge on CD's? That's something I've never heard of!!

Weel duh - early withdrawal penalties

Speaking of early withdrawal penalties, we changed ours a few months ago and have eased into the harsher penalties as NEW CDs are opened.

Now we are having second thoughts, and would like to roll back to the way we were. That would mean only the new CD holders have seen the discription of the harsher penalties. Those that roll stay the same.

I'm not finding any mention of subsequent disclosures for a change that benefits the account holder in Reg DD.

Am I understand that correctly! Also Randy, you mention that the vendor forms are not good for describing the early withdrawal penalties. What do you typically see missing?

I've never seen a pre-designed form that didn't have blank spaces for use in inserting additional terms specific to a bank's policies and procedures. They generally start with the generic terminology and then we must customize to fit our specific account(s). I say generally because I have seen two forms pre-filled with information that could vary based on Reg DD, rendering the forms useless for several of our CD accounts.