Reg D: Unlimited Transfers for in-person transactions?
Answers by Ken Golliher and John Burnett, BOL Gurus
Question: After reading Reg D several times, I still have questions. If I understand it correctly, a customer can withdraw or transfer from a savings account as many times as he chooses if it's in person. Is this your understanding?
Answer by Ken Golliher: BIO AND CONTACT INFO
Yes, the regulation does not require you to include "in person" withdrawals (along with several other types) when calculating the number of transfers made in a particular calendar month or statement cycle.
However, your bank is free to count anything it wants in in designing its products, as long as you are at least as restrictive as the regulation. For example, my bank's MMDA pays a better than market rate, but only allows three debits per calendar month or statement cycle before imposing a punitive fee. If I write one check, use the ATM once and make an in-person withdrawal, I am done for the month.
Answer by John Burnett: BIO AND CONTACT INFO
When I'm discussing the transfer limits in training or with customers, I try to simplify the rule a little by using my own version of the "travel rule."
Simply put, the general rule is that if you have to travel (from your office or home) to make the transfer (to the bank or an ATM) the transfer doesn't count against the limits. The flip side of that is that transfers you can make from the comfort of your home or office (including those you make by check) will count.
[Editors Note: As of 7/2/09, the separate limit of three per month for checks, POS debit card transactions, etc., has been eliminated, and those transactions are now only subject to the 6/month limit that applies to other restricted transfers and withdrawals.]
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