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#100041 - 07/23/03 08:32 PM Penalties for Reg D Violation
Anonymous
Unregistered

Could anyone direct me to a source that states
what the penalty for Reg D violations are. Such
as letting customers exceed withdrawal limits on
savings accounts?

Thanks for any help.

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Operations Compliance
#100042 - 07/23/03 08:39 PM Re: Penalties for Reg D Violation
Deena Offline
Power Poster
Deena
Joined: Nov 2000
Posts: 2,701
PA
Your biggest "penalty" would be if you are found to be treating savings (including MMAs) accounts as transaction accounts but not reserving for them accordingly. In this case, the examiners may make you reclassify all of your savings accounts as transaction accounts and re-reserve for them going back several years. This can add up to a lot of money. It's much more efficient to comply with the transaction limitations.
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Opinions expressed are mine and not necessarily those of my employer.

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#100043 - 07/23/03 09:20 PM Re: Penalties for Reg D Violation
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,749
On the Net
The file searches and revised call reports can cost as much or more than the reserves, from what I have been told.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#100044 - 07/23/03 09:23 PM Re: Penalties for Reg D Violation
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
Deena is right: here is section 204.7, Reg D's penalty section.

The big kicker here is that if you do not have effective controls to enforce the savings account transaction restrictions, the Fed can reclassify all your MMDA or savings accounts as transaction accounts, not just one account.
Last edited by John Burnett; 07/23/03 09:37 PM.
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