Our forms provider recently updated the Terms and Conditions for our demand deposit and savings accounts. Should we also provide updated Terms and Conditions for our certificate of deposit (CD) and individual retirement account (IRA) customers?

Whether you update the Terms and Conditions for your CD and IRA customers depends on whether your bank plans to provide those accounts under the same terms as your demand deposit and savings accounts.

As a guiding principle, your Terms and Conditions should accurately reflect your practices for the affected accounts. It is possible to have different Terms and Conditions for different account types if your practices differ for those accounts. If you choose to update your CD and IRA Terms and Conditions, then you will have to ensure that your practices for CDs and IRAs match the practices described in your updated Terms and Conditions.

For resources related to our guidance, please see:

  • Regulation DD, 12 CFR 1030.3(b) (“General. The disclosures shall reflect the terms of the legal obligation of the account agreement between the consumer and the depository institution. Disclosures may be made in languages other than English, provided the disclosures are available in English upon request.”)