Strengthen Penalties On CD Maturities: Time Frame

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Question:

We are looking to change (strengthen) the penalties on CD maturities - what type or time frame of notice do we have to provide for those changes going forward?

Answer:

You will have to phase in those increased penalties as current CD accounts mature. You will describe the changed early withdrawal penalty provision in or with the maturity notice that you send pursuant to Regulation DD section 1030.5(b). Other than that, there is no federal requirement for an advance notice.

Make sure your platform personnel are aware of the change.