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Question & Answer
Question: We've been following the HOTLINE Q & A on the MMDA accounts, and how to determine six transactions. It really has helped. My question is do we have to provide the disclosure on passbook savings and statement savings accounts? It seems as though the rules were made for commercial accounts. I'm concerned with our individual accounts. Are they also covered and restricted to the six transactions?
Answer: They sure are. And you should be giving those disclosures to customers who open those accounts. The whole premise of Regulation D has to do with the reserve requirements on transaction accounts. Statement savings, passbook savings and MMDA accounts are all "savings accounts," which currently have no reserve requirement and therefore differ from transaction accounts. The requirement to limit the transactions still applies to all "savings accounts."
(Thanks one more time to Phil Farley, Manager, Regulatory Assistance, FRB, Philadelphia)
Copyright © 1997 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 7, No. 10, 8/97
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