No, we do not believe these disclosures are required for IRAs.

Regulation CC governs the availability of funds for transaction accounts and the holds banks can place on checks. Its disclosure requirements related to funds availability and substitute checks do not apply to IRAs, which are excluded from Regulation CC’s definition of a “transaction account.”

Regulation E governs the rules for electronic funds transfers. Its disclosure requirements also do not apply to IRAs, which are considered to be “account[s] held by a financial institution under bona fide trust agreement” and are excluded from Regulation E’s definition of an “account.”

For resources related to our guidance, please see:

• Regulation CC, 12 CFR 229.2(a)(1) (“Except as provided in paragraphs (a)(2) and (a)(3) of this section, account means a deposit as defined in 12 CFR 204.2(a)(1)(i) that is a transaction account as described in 12 CFR 204.2(e). As defined in these sections, account generally includes accounts at a bank from which the account holder is permitted to make transfers or withdrawals by negotiable or transferable instrument, payment order of withdrawal, telephone transfer, electronic payment, or other similar means for the purpose of making payments or transfers to third persons or others. Account also includes accounts at a bank from which the account holder may make third party payments at an ATM, remote service unit, or other electronic device, including by debit card, but the term does not include savings deposits or accounts described in 12 CFR 204.2(d)(2) even though such accounts permit third party transfers. An account may be in the form of (i) A demand deposit account, (ii) A negotiable order of withdrawal account, (iii) A share draft account, (iv) An automatic transfer account, or (v) Any other transaction account described in 12 CFR 204.2(e).”)

• Regulation D, 12 CFR 204.2(e) (“Transaction account includes: . . . (6) All deposits other than time and savings accounts, including those accounts that are time and savings deposits in form but that the Board has determined, by rule or order, to be transaction accounts.”)

• Regulation D, 12 CFR 204.2(c)(1)(i)(a) (“Time deposit includes funds . . . Where the time deposit is maintained in an individual retirement account established in accordance with 26 U.S.C. 408 and is paid within seven days after establishment of the individual retirement account pursuant to 26 CFR 1.408-6(d)(4) . . .”)

• Regulation E, 12 CFR 1005.7(a) (“A financial institution shall make the disclosures required by this section at the time a consumer contracts for an electronic fund transfer service or before the first electronic fund transfer is made involving the consumer’s account.”)

• Regulation E, 12 CFR 1005.2(b) (“(1) ‘Account’ means a demand deposit (checking), savings, or other consumer asset account (other than an occasional or incidental credit balance in a credit plan) held directly or indirectly by a financial institution and established primarily for personal, family, or household purposes. (2) The term does not include an account held by a financial institution under a bona fide trust agreement.”)

• Regulation E, Official Interpretations, Paragraph 2(b)(2), Comment 2. (“Custodial agreements. An account held under a custodial agreement that qualifies as a trust under the Internal Revenue Code, such as an individual retirement account, is considered to be held under a trust agreement for purposes of Regulation E.”)