TISA requires financial institutions to provide Certificate of Deposit (CD) maturity notices, the content and timing of which depend on the term of the CD and whether or not it renews automatically. This is an area where institutions tend to rely on their systems and, in a sense, “set it and forget it”. Even so, it’s still common for our review team to find notices that lack the required information or are not sent within the required timeframes.
Some of the most common errors we see have to do with the content of the maturity notice. One example is that sometimes the information disclosed on the notice is not specific to that particular CD. For example, the early withdrawal penalty disclosed on the maturity notice is not the actual early withdrawal penalty that will apply when the CD renews. The requirements for CD maturity notices can be found in §1030.5(b) and (c). We also addressed this in our April issue of Banking on BCC.
On another note, if you are providing more than one renewal/maturity-related notice for CDs, you are doing more and likely spending more than necessary. TISA technically only requires one CD maturity notice be provided. A lot of systems call this an “approaching renewal advice” or something similar. We have seen additional notices provided that are sometimes called an “interest advice”, “maturity advice”, etc., that are not required by regulation. If you feel they are beneficial to your customers, you can certainly continue to provide them as a customer service, but again, multiple notices are not required.
While your systems do play a large part in this process, each one does things a little differently and they aren’t necessarily foolproof. The key from a compliance perspective is ensuring that consumers get the information they are required to get, when they are required to get it.
Published
2025/06/13
