No, we do not believe you are required to pay accrued interest if a customer closes a deposit account or CD before the date on which the interest is credited — provided that you have properly disclosed that customers may forfeit accrued interest if they close the account before the interest is credited.

Regulation DD’s Official Interpretations confirm that “[s]ubject to state or other law, an institution may choose not to pay accrued interest if consumers close an account prior to the date accrued interest is credited, as long as the institution has disclosed that fact.” In such cases, the account opening disclosures must include a statement that consumers will forfeit interest if they close their account before accrued interest is credited and that interest will not be paid.

We are not aware of any Illinois or other law that would require you to pay accrued, uncredited interest when a customer closes an account. Consequently, we do not believe you are required to pay such interest when a customer closes an account or CD, provided that the forfeiture of interest is disclosed at account opening.

For resources related to our guidance, please see:

• Regulation DD, Official Interpretations, Paragraph 7(b), Comment 3 (“Subject to state or other law, an institution may choose not to pay accrued interest if consumers close an account prior to the date accrued interest is credited, as long as the institution has disclosed that fact.”)

• Regulation DD, 12 CFR 1030.4(b) (“Account disclosures shall include the following, as applicable: . . . (2) If consumers will forfeit interest if they close the account before accrued interest is credited, a statement that interest will not be paid in such cases.”)

• Regulation DD, 12 CFR 1030.2(a) (“Account means a deposit account at a depository institution that is held by or offered to a consumer. It includes time, demand, savings, and negotiable order of withdrawal accounts.”)