Thank you to anonymous for the phone number. This question also came up today at my bank. I attended the PA Treasury Dept seminar last year and asked this question, but since it came up again I also called them today to confirm the answer. They said the five year clock starts ticking on the first maturity date for automatically renewable CDs if there is no customer contact. Their logic is that the CD can be rolling indefinitely if the customer is not actually receiving the renewal notices. They also indicated that even if the interest is being deposited to another account at the bank, we must still contact the customer to verify that they are aware that the CD is here. However, if the customer has other accounts, you can call them and document the phone call rather than get something signed, if you prefer. Hope this helps. While it makes sense to me, it is definitely an operational nightmare.