Compliance Blog

Share Certificate Maturity Notices

Written By: Reginald Watson, NAFCU Regulatory Compliance Counsel

Greetings Compliance Friends!

The NAFCU Compliance Team periodically receives questions on renewal notices for share certificate accounts, and unfortunately NCUA’s rules governing maturity notices are not in the clearest of formats. As discussed in a previous blog, credit unions are generally required to provide notice to members at least 30 days prior to any account changes that may reduce the annual percentage yield or adversely affect the member.  When it comes to share certificates approaching maturity, section 707.5(b) of NCUA’s Truth in Savings Rule (TIS) provides more specific notice  requirements which vary depending upon the length of the share certificate and whether or not it is set to renew automatically upon maturity. Understanding these requirements may become even more cumbersome when considering the breadth of a credit union’s changing product mix over time.

Although the terms of an agreement may not change upon the renewal of a share certificate, NCUA considers a share certificate renewal to represent a new formal banking relationship and thus a new account. That being said, full new account disclosures containing the information required by section 707.4(b) of TIS are not always required in every circumstance. The following chart outlines the minimum notice requirements applicable to different share certificate account types, and the minimum timing requirements for providing notice under NCUA’s Truth in Savings rules:

Share Certificate
Maturity Type

Automatic Renewal?

Content Required

How Advanced?

One Month Or Less

Yes

No Notice Required

One Month Or Less

No

No Notice Required

Longer Than 1 Month, But Not More Than 1 Year

Yes

Either full new account disclosures under §707.4(b), or:

·    The date the existing account matures and the new maturity date. 

·    Any changes in the account terms of the new account.

·    The new dividend rate and APY.

·    If the dividend rate and APY are unknown, the date when they will be determined, and a telephone number for the member to obtain the new dividend rate and APY.

30 calendar days before maturity, or alternatively,
20 calendar days
before the end of
any grace period.

Longer Than 1 Month, But Not More Than 1 Year

No

·    No notice required.

·    If independently renewed by the member, full new account disclosures.

Longer Than 1 Year

Yes

·    The date the existing account matures.

·    Full new account disclosures.

30 calendar days before maturity, or alternatively, 20 calendar days before the end of any grace period.

Longer Than 1 Year

No

The maturity date and whether dividends will be paid after maturity.

10 calendar days
before maturity.

It is my understanding that many credit unions often make the business decision to provide the same maturity notice and full new account disclosures for all types of share certificate accounts as a matter of internal policy, but that is a risk-based decision.


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About the Author

Reginald Watson, NCCO, Regulatory Compliance Counsel, NAFCU

Reginald Watson, NCCO, Regulatory Compliance CounselReginald Watson, NCCO, was named regulatory compliance counsel in August 2017. In this role, Watson helps credit unions with a variety of compliance issues.

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