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If a predecessor bank offered CDs on terms that we do not offer, how should we notify customers of the change? – IBA Compliance Connection

If a predecessor bank offered CDs on terms that we do not offer, how should we notify customers of the change?

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We believe that a change in terms notice would be required to inform customers that they will be losing the deposit option after the next automatic renewal. Specific rules in Regulation DD address change in terms notices for time accounts that renew automatically and that have a term of one year or less (but more than one month). Those rules authorize two options for making prematurity change in terms notices: (1) providing new account disclosures for the new account and disclosing the maturity date of the existing account or (2) making three specified disclosures (maturity dates for the existing account and the new account, the interest rate and APY (if known), and any differences in terms between the accounts). 12 CFR 1030.5(b)(2). You must send the prematurity change in terms notices at least thirty calendar days before the existing account matures (or, if the account allows a grace period of at least five days, you may send the notices at least twenty calendar days before the end of the grace period). 12 CFR 1030.5(b).