I’ve written about TIAA’s “Marketsafe CD” products, and those issued by Everbank prior to its acquisition by TIAA. I’ve suggested that the offering of these products violates the 1933 Securities Act, and I maintain that position. More importantly, I have always written to advise depositors to avoid thinking of these products as CDs (they should not be called CDs), and I am doing that again here.

The latest product purports to give depositors so-called “safe” exposure to the Brazilian Real, the Euro and gold and emerging market equities. In this case, these assets are all priced using ETFs on a pricing date, and then measured against the price of those ETFs in 4 years. The investor gets back their principal and the weighted appreciation, if any, at maturity. Interestingly, the video, featuring Chris Gaffney, uses the hypothetical appreciation of 6% over 4 years which would underperform by at least half the compounded performance on a 4-year CD (where you can still earn well over 3% per year).

With its past products, TIAA and Everbank provided some rationale for tying their products together. They represented earlier products as a play on oil currencies here and here a play on emerging market currencies here or emerging market equities here or a rise in interest rates here or here.

I am not sure of the rationale for tying together the Brazilian Real, the Euro, gold and emerging market equities. It now seems to be a kind of “we think you’ll like this” type of thing. A prudent investor might look at which of these things they want to own and invest in them though the ETF directly or some other means. For example, my own personal opinion is that while gold and the Euro might appreciate against the dollar over the coming 4 years, the Brazilian Real and the emerging market ETF could easily fall quite severely. I would look at the gold ETFs (IAU or GLD) as one alternative, and interest-earning Euro accounts as another.

As anyone who has invested in any of TIAA’s or EverBank’s Marketsafe products knows, it just takes one nasty thing in the basket to destroy it and to leave you waiting for maturity to get your principal back. Previously, however, TIAA damaged your wealth but did not hit you with a 1099 reporting Original Issue Discount (OID). However, if you read the terms of the latest offering, TIAA will hit you with an OID statement for imputed interest in each of the four years that you are holding this product. While the bank would have had an obligation under Federal Tax law to have reported OID, EverBank did not do this prior to its acquisition and the fact that they are now doing it means that their products go from a dreadful idea to a ever worse one.

Bottom line: Continue to avoid TIAA Marketsafe CDs.

Interest rates have collapsed over the last several weeks and that may be good news for those interested in remortgaging or buying a new property. It is also good news for anyone considering taking out a new home equity loan or line of credit or an auto loan.

It may not be good news for your savings. Many banks dropped their online savings rates going into the July rate cut and still others are dropping their rates now based on the assumption that the Fed is not done cutting.

We are getting a lot of notes from savers who remember well a lengthy period from 2009 to 2016 when savings rates were below 1%, and are terribly fearful that we may be heading back there. Indeed, anyone looking at Japanese or German rates and watching the talking heads on CNBC or Bloomberg can get the feeling that there is a real paradigm shift and that interest rates are never going up.

There are still banks and credit unions that are offering online 5-year CDs over 3%. In your local market, you may even find brick and mortar opportunities at banks and credit unions to get these kinds of rates.

Here are two reasons why you should be cautious.

First, we’ve seen a panicked move in Treasuries. Rates may not stay this low for very long. We could be in a completely different environment in a year or 18 months with the 10-year back over 3% and perhaps even with the Fed Funds rate back over 3%. If that happens, you will regret having limited your liquidity by locking into a long-term CD.

Second, even if rates go back to zero, you are still going to see attractive 5-year CD offers as banks will still need to lock up long-term deposits from depositors to fill their capital needs. From 2011 until 2015, while the Fed Funds rate was at zero and the best savings rates were below 1%, it was still always possible to find 5-year CDs at or just under 2.50%. So, even if we see a continued complete collapse in interest rates, you will always be able to get a premium for locking in for a long period. And, yes, there is a difference between 2.50% and 3.50%, but the difference is not a matter of life or death (especially after you calculate the net income from the CD after tax).

If you see 5-year CDs as a sort of insurance against collapsing rates, then you can go ahead and devote a small amount of your savings to provide some level of protection against falling rates (be sure to check the best rates here). But, we’d be much more inclined to direct that energy towards one-year CDs where the rates may be slightly lower, but so is the risk of getting this wrong.

Amazingly, Jim Cramer, the biggest proponent of the stock market was interviewed on NBC’s Today show the other day and couldn't say anything other than to buy CDs.

It is a video so extraordinary that you need to watch it here.

To be clear, BestCashCow thinks that CDs should always be an important part of a well-diversified, safe portfolio. We provide the most comprehensive list of the best online CD rates here, and we also encourage folks to look at rates at banks near them and at credit unions near them.

But, we’ve been suggesting people take extreme caution around anything longer than a year, even though two-year CD rates are now above 3% and may attract attention. In fact, I wrote just yesterday that I do not find a one-year CD at 2.85% APY to be particularly attractive since online savings rates are strong and the Fed is still raising rates.

But, what is quite extraordinary here is that Cramer could be so easily perturbed (to put it mildly) by the recent market volatility. This is, in fact, the same man who was encouraging people to buy into Facebook at 200, Nvidia at 290, and Amazon at 2000 in November.

I speak at conferences and extol the virtues of CDs, but I certainly wouldn’t tell people to run out of the market here, and I have no intention of unloading my Nvidia or Amazon at this time.

So what is Cramer afraid of? I, for one, suspect he just trying to create a record of saying everything imaginable in the most vague way possible so that he can point to it and say he was right (especially if we have a 2009 scenario and he winds up on the Daily Show again).