For those that offer online Bill Pay, do you limit the designation of the Primary OnLine Banking account to one that IS NOT either a MMDA or Savings Acct?

The last bank I was at did so due to the Reg. D Excess Transactions limitations. The current bank I am at will be implementing OnLine Banking and Bill Pay soon and had not yet discussed this (I think) important issue.

Thanks in advance.

For us - must be a normal DDA account.

Same here.

I will be interested in what others reply…
I have always considered only the regular DDA (not NOW) checking account as the only option, to do otherwise will be limited by Reg D and then the bill paying feature is very limited. (Kinda against it’s purpose…)

(Revised to be nit free!)

We require regular DDA account... same reasons as above.

Just because my business is picking nits, I'll jump in here and assume that all references above to "DDA" mean "transaction account," and include NOW accounts.

Why would you not allow NOW accounts as the primary account to pay from ? Most consumers have NOWs, not DDAs.

Ok, Ok we have some NOWs used as primary. A significantly higher balance is needed to have a NOW account without monthly fees. We have several types of (non-interest bearing) checking accounts that require a balance less than NOWs down to $0. At least in our market, many – not most – customers have regular checking accounts (not NOWs).

Back to the original poster’s question… as far as I know, there is no regulatory restriction on what type of account can be used as the primary for bill pay. As pointed out, if a Sav or MMA is used, there are withdrawal limits. So, if the customer exceeds the w/ds enough times they’ll get a DDA (at FAB they’ll get a NOW.)

Up until last week we could only do one primary account for bill pay and we allowed any checking account. We now have the ability to have multiple funding accounts, but we still limit it to checking accounts because of the reg D issues.

(The system will notify us if they go over the Reg D limit, but we don't want to deal with the customer service problems of upset customers).