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With a quarterly statement, can a customer have 18 Reg D withdrawals?
Answer by John Burnett, BOL Guru
BIO AND CONTACT INFO
Question: If our bank’s statement cycle for savings accounts is quarterly, would we be in compliance with Regulation D by limiting withdrawals to 18 per statement cycle as opposed to 6 per month?
Answer: No.
The regulation requires that the limits on activity be on a per-month basis (or statement cycle of at least 4 weeks). So, if you want to count the transfers per quarterly cycle, you'd still be limited to 6, not 18.
Another way of looking at this is that your customer could readily complete all 18 transfers in 1 day under an 18/quarter limit, and be in clear violation of the 6/month rule.
First published on BankersOnline.com 9/2/03

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