Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
When we issue a certificate of deposit (CD), we include the Truth in Savings Act (TISA) disclosures and the terms of the account agreement on the CD, which the customer signs. After a CD matures, some customers call to request a new CD with a longer or shorter term. In these cases, we mail the customer a new CD that contains the new disclosures and the new account terms, but we do not obtain their signature. Our auditors say a signature is required on the new CD. Is that correct? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

When we issue a certificate of deposit (CD), we include the Truth in Savings Act (TISA) disclosures and the terms of the account agreement on the CD, which the customer signs. After a CD matures, some customers call to request a new CD with a longer or shorter term. In these cases, we mail the customer a new CD that contains the new disclosures and the new account terms, but we do not obtain their signature. Our auditors say a signature is required on the new CD. Is that correct?

—

by

We are not aware of any requirement in the Truth in Savings Act or otherwise mandating that a customer sign a CD. However, we do recommend requiring the customer to sign a new account agreement when switching to a new CD account that has a different term. If your account agreement is included on your CD, then your customer should sign the new CD.

The account agreement is the instrument by which customers bind themselves to the terms of a specific account. When a customer requests a new CD that will have a different term, the customer should sign a new agreement reflecting that new term. In our view, providing the new CD without obtaining a signature risks insufficiently binding the customer to all of the terms of that new account.

We are aware that some institutions have customers sign master CD agreements that cover all CDs purchased by that customer. However, from what you have told us, your institution is not using a master CD agreement, and consequently we recommend obtaining new signatures for each new CD.