CD Discussion Thread

This is for those who do not have an account with Ally Bank. Ally Bank customers already have received notice of this:

Apparently the FDIC, commencing in the spring, will be more insistent about CD account owners providing their beneficiaries’ social security numbers to the bank. It would seem the great minds at the FDIC assume we account owners know that number for everyone on our beneficiary list.

The FDIC: WABOA

Myself personally:

I began a couple of years ago an effort (asset spreading) to keep all my account balances, at a given financial institution, below the magical quarter mil mark. This obviates need for beneficiaries in the first place. Little did I realize, until now, the wisdom of this approach. :wink:

I can just see that conversation.

Bob: Hey give me your social security number.
Jim: Why on earth would I do that?
Bob: I have you as my beneficiary on blah blah blah.
Jim: Oh really?

6 months later Bob dies from a fatal dose of Arsenic added to his lunch. Coming soon to a detective drama tv show in your area.

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Here is more detail straight from the new FDIC rules:

§ 370.4 Recordkeeping requirements.

(a) General recordkeeping requirements. Except as otherwise provided in paragraphs (b), ©, and (d) of this section, a covered institution must maintain in its deposit account records for each account the information necessary for its information technology system to meet the requirements set forth in § 370.3. The information must include:

(1) The unique identifier of each:

(i) Account holder;

(ii) Beneficial owner of a deposit, if the account holder is not the beneficial owner; and

(iii) Grantor and each beneficiary, if the deposit account is held in connection with an informal revocable trust that is insured pursuant to 12 CFR 330.10 (e.g., payable-on-death accounts, in-trust-for accounts, and Totten Trust accounts).

(2) The applicable ownership right and capacity code listed and described in Appendix A to this part.

(b) Alternative recordkeeping requirements. As permitted under this paragraph, a covered institution may maintain in its deposit account records less information than is required under paragraph (a) of this section.

(1) For each deposit account for which a covered institution’s deposit account records disclose the existence of a relationship which might provide a basis for additional deposit insurance in accordance with 12 CFR 330.5 or 330.7 and for which the covered institution does not maintain information that would be needed for its information technology system to meet the requirements set forth in § 370.3, the covered institution must maintain, at a minimum, the following in its deposit account records:

(i) The unique identifier of the account holder; and

(ii) The corresponding “pending reason” code listed in data field 2 of the pending file format set forth in Appendix B (and need not maintain a “right and capacity” code).

(2) For each formal revocable trust account that is insured as described in 12 CFR 330.10 and for each irrevocable trust account that is insured as described in either 12 CFR 330.12 or 12 CFR 330.13, and for which the covered institution does not maintain the information that would be needed for its information technology system to meet the requirements set forth in § 370.3, the covered institution must, at a minimum, maintain in its deposit account records:

(i) The unique identifier of the account holder;

(ii) The unique identifier of a grantor if the deposit account has transactional features (unless the account is insured as described in 12 CFR 330.12, in which case the unique identifier of a grantor need not be maintained for purposes of this part); and

(iii) The corresponding “right and capacity” code listed in data field 4 of the pending file format set forth in Appendix B if it can be identified, otherwise the corresponding “pending reason” code from data field 2 of the pending file format set forth in Appendix B.

© Recordkeeping requirements for official items. A covered institution must maintain in its deposit account records the information needed for its information technology system to meet the requirements set forth in § 370.3 with respect to accounts held in the name of the covered institution from which withdrawals are made to honor a payment instrument issued by the covered institution, such as a certified check, loan disbursement check, interest check, traveler’s check, expense check, official check, cashier’s check, money order, or similar payment instrument. To the extent that the covered institution does not have such information, it need only maintain in its deposit account records for those accounts the corresponding “pending reason” code listed in data field 2 of the pending file format set forth in Appendix B (and need not maintain a “right and capacity” code).

(d) Recordkeeping requirements for deposits resulting from credit balances on an account for debt owed to the covered institution. A covered institution is not required to meet the recordkeeping requirements of paragraphs (a) or (b) of this section with respect to deposit liabilities reflected as credit balances on an account for debt owed to the covered institution if its information technology system is capable of:

(1) Immediately upon failure, restricting access to all of the deposits in every borrower’s deposit account(s) at the covered institution in accordance with § 370.3(b)(3); and

(2) Producing a file in the format provided in Appendix C to this part 370 for:

(i) Credit balances on open-end credit accounts (revolving credit lines) such as credit card accounts and home equity lines of credit within a time frame that will allow the covered institution’s information technology system to meet the requirements set forth in § 370.3(b)(1), (2) and (4) within 24 hours after failure; and

(ii) Credit balances on closed-end loan accounts that can be used by the covered institution’s information technology system to meet the requirements set forth in § 370.3(b)(1), (2) and (4).

[Codified to 12 C.F.R. § 370.4]

Please note I am here merely your humble messenger. Please do not shoot the messenger! While social security numbers are not specifically mentioned, what other “unique identifier” do we all possess?

While I’m not sure I like the increased scrutiny, I’d imagine this is not that far of a stretch as far as assumptions go. As other identifier, they could go with drivers license too.

For the vast majority of them, these are family members you should know the numbers of (spouses & kids especially). But I don’t know how they’d handle things if the designated beneficiaries are not US residents (or anyone without a SSN number).

We’ll see how it pans out and whether they will enforce it on newly opened CDs or force it to be retroactive on already opened CDs. Adding all the numbers to the variety of CDs we have including some we don’t have that much money in, sure would be a pain.

And for those of us with a little more gray, we remember Art Fern using that line before many of the “In Living Color” cast were in grade school … or possbily born. :smile:

Or …

6 months later Jim starts receiving collection calls for accounts that he never opened, and wonders why he didn’t freeze his credit when Uncle Bob asked for his SS#. :wink:

I was able to get in on a decent local CD last month and the CU insisted that I provide SS#s for each of the beneficiaries I listed. I didn’t particularly like it, but they would not allow a beneficiary without one. I suggested that one of the beneficiaries was not a U.S. citizen and did not have a SS#. He didn’t bat an eye and said I’d have to provide their TIN (Taxpayer ID Number).

There should be an option to flag these cases as foreign beneficiaries just like you would on retirement account beneficiaries. The corresponding flat 30% tax withholding on distributions to such beneficiaries should be enough incentive to have people not use that option too often.

But I like the nonsensical response… Very “let them eat cake” like.

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Art Fern was Johnny Carson I assume?

Yepper!

I’ve been thinking about these Keesler 30 M 3.2% CD’s. :relaxed:

I do have enough money over at Grow MM to go ahead & open this CD. I also have a large CD that will matures 2/2/20 that I could replace the funds at Grow.

Question… would you take the chance that Keesler might drop this CD & move funds out of Grow, to open the CD?
Or wait until the CD on 2/2/20 matures & use those funds to open this CD? (if offer is still there)

A bird in the hand is worth two in the bush. If you have enough money to grab that 3.2%, and if you only would have to wait, as you say, a matter of less than two weeks in order once again to regain your liquid funds position, and if the Keesler CD is otherwise right for your overall investing strategies, then acting now would be a screaming no brainer . . . were it me.

I have no clue what Keesler will do at any point in the future. But where else, aside from add-on CD opportunities you might have provided for yourself in advance, are you gonna be able to find a 30 month CD with that kind of return?

And the nice thing about going with Keesler, even if you do have add-on opportunities in your back pocket, is that you keep that add-on CD space open for future maturing CDs.

Thanks! I think I will take Keesler’s CD right now.

I don’t blame you. I called them and according to the person I spoke with in new accounts, they have not been slammed. That surpised me, but I suppose all of the interested parties have already created their accounts.

Also, the lady that I spoke with didn’t inspire confidence. She may never get busy. :smile:

Just as a reminder, and this is about the hundredth time I have offered this, but remember the Keesler CD is only for money you are absolutely certain you will not need prior to maturity.

Other than that, it’s a wonderful deal.

I think you’re asking about the chance of being screwed, and the rate dropping while your funds are in transit? Indications have been that their rate sheet updates on Wednesdays, so there’s a good chance you have at least until next Tuesday to get it open.

I agree with Shin, that there’s no use keeping money at the liquid rate, if you’re just going to dump it into this CD anyways (although technically you will be earning less for the first 10-month step).

Also remember, the jumbo CD is only one tenth of one percent better - so there’s an advantage of sending them $100k, but it’s only a very small advantage.

You mentioned the early withdrawal penalty being steep. But just as important is understanding the rate structure - you’re earning significantly less than the APY the first 1/3 of the term, and need the high rate for the final 1/3 to even make the CD worthwhile at all. That’s before considering the early withdrawal fee, which is just twisting the dagger more.

Thanks, glitch99… I’m moving funds tomorrow Thursday, which will not arrive at Alliant CU until Friday. So it will take up to next Tuesday (if I’m lucky) to fund the Keesler CD. So many steps. :rage:

If these CU’s were close by, funding accounts would be a breeze. But never happens…

My comments right along, for a long time, have been all inclusive. Way I’m putting it now is simply:

Don’t invest unless you can leave the money with Keesler until maturity.

That pretty much covers everything. For anyone who might need to close their CD early, this is not the CD for you. Look elsewhere.

I assume you are going for the 3.2% . . . so it’s a jumbo situation. Given that, have you considered wiring the funds straight to Keesler? OK, so it costs a few bucks. Might be worth it, you would have your new CD before the weekend, and you could kick back and celebrate. :grinning:

Oh, wait. Sorry. You mentioned Alliant. You can only send out a max of $25k/day at Alliant. So it’s not a jumbo, and doing a wire for the smaller amount might not be worth the cost. Oh, well. :roll_eyes:

Shinobi, I don’t there are any restrictions on the amount of money you can wire out of Alliant. I think you’re referring to ACH withdrawals.