If you draft the account opening disclosures correctly, a change in terms notice will not be necessary. Because the certificate of deposit (CD) account terms will automatically change when the CDs mature, you do not need to send an advanced notice of the changes that occur on maturity, provided that you clearly describe the conditions of the changes in your account opening disclosures.

As stated in the official commentary to Regulation DD, “[a]n institution offering terms that will automatically change upon the occurrence of a stated event need not send an advance notice of the change provided the institution fully describes the conditions of the change in the account opening disclosures . . . .” Official Interpretations, 12 CFR 1030, Paragraph 5(a)(a)(1) Comment 3. The commentary gives the example of a promotion described in the account opening disclosures as “waiv[ing] $4.00 monthly service charges for one year” — when the one year is up, the commentary states that an advance change-in-terms notice is not required. Official Interpretations, 12 CFR 1030, Paragraph 5(a)(a)(1) Comment 4.

Note that for any automatically renewing CDs with maturities longer than one year, you must provide prematurity notices before the CDs mature. 12 CFR 1030.5(b)(1). The prematurity notices should include the account opening disclosures and the date on which the account will mature, but you do not need to highlight terms that have changed since the last account disclosure was provided. Official Interpretations, 12 CFR 1030, Paragraph 5(b)(1) Comment 1.