Is this feature a "callable" feature under the time deposit rules in Reg DD?

New CD product - customer can have one withdrawal of up to 25% of original principal balance without incurring early withdrawal penalty. Any other withdrawal requests after the first one requires that CD be closed, with penalty. Is the closing of the CD the "callable" feature in Reg DD? I'm thinking that it does. Account disclosures will need to include and describe the circumstances triggering closing the CD. Marketing materials also? PLEASE CONFIRM, or enlighten me. Thanks very much.

As described, this CD would not be considered a "callable" CD. You just have a different type of early withdrawl penalty. A "callable" CD is callable by the institution at the institution's option, not based on a activity initiated by the customer.

One more question please. Do the Reg DD disclosures need to include this early withdrawal penalty (closing of the CD)? We already disclose the other standard w. penalties.

Thank you.

Since a 25% withdrawal is allowed without a penalty and it is a feature of the account, that should be disclosed separate from the remaining penalties for further withdrawals..