I'm reviewing our disclosures for TISA compliance. On time accounts we currently provide a disclosure that shows the number of months for the maturity: example-"your account will mature in 60 months". We also provide them a CD form which does contain the actual maturity date. However, on the CD it states that they must surrender the CD when they withdraw funds, transfer or close the account.

My question is in regards to the fact that they must surrender the CD at some point. Will this fact result in us running afoul of the provision that the disclosures must be in a form that the consumer can retain?

Will we need to provide a separate disclosure that states the maturity date?

Your concerns are correct. If a required item of disclosure is on the CD itself, and you make the customer surrender the CD, you've made it something he cannot retain. It doesn't matter than the lack of that piece of information means nothing after the CD is cashed in.

You can get around the problem by providing a copy of the CD at the time you open the account (customer gets original and marked copy), or by giving back a copy when the consumer turns the original in.

Thanks, that's exactly the type of information I was looking for.