If a customer calls in and requests a check withdrawal made payable to themselves, is this considered one of the 6 limited withdrawals or is this considered unlimited?

These would be unlimited. This quote is from the definition of a savings account under Reg D.

"Such an account is not a transaction account by virtue of an arrangement that permits transfers for the purpose of repaying loans and associated expenses at the same depository institution (as originator or servicer) or that permits transfers of funds from this account to another account of the same depositor at the same institution or permits withdrawals (payments directly to the depositor) from the account when such transfers or withdrawals are made by mail, messenger, automated teller machine, or in person or when such withdrawals are made by telephone (via check mailed to the depositor) regardless of the number of such transfers or withdrawals."

Deena is right on.

This ties to the "convenience" rule of thumb. IF it is convenient, it counts, if it isn't, it doesn't. Mailing a check to them is inconvenient. If they wanted it placed in their checking account, however, that would be convenient and it would count.

How about faxed requests for transfers from savings to checking? There's been some debate about it around here...

Unlimited: It's got a signature, so it falls under the same category as a mailed request.

Limited: It comes over the phone, so it falls under the telephone request category (just like requests that come over the Internet).

Opinions? Actual citations? Anyone?

There is no limit to the number of withdrawals made in person, at an ATM or by a check payable to the account holder when requested via messenger, fax, mail, or phone. Other transfers from these accounts, including Electronic Payments, telephone and online banking transfers, are limited to six per month with only three of the six transfers by check or Point-of-Sale debit card.

Faxes are included in the "limited" number of transactions. Here's the quote from the definition of savings account in Reg D (with my emphasis added):

" (2) The term savings deposit also means: A deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or as a money market deposit account (MMDA), that otherwise meets the requirements of Sec. 204.2(d)(1) and from which, under the terms of the deposit contract or by practice of the depository institution, the depositor is permitted or authorized to make no more than six transfers and withdrawals, or a combination of such transfers and withdrawals, per calendar month or statement cycle (or similar period) of at least four weeks, to another account (including a transaction account) of the depositor at the same institution or to a third party by means of a preauthorized or automatic transfer, or telephonic (including data transmission) agreement, order or instruction, and no more than three of the six such transfers may be made by check, draft, debit card, or similar order made by the depositor and payable to third parties."

I was trying to answer TISA's question, which was whether a faxed request to transfer funds from a checking to a savings account would be "limited" or "unlimited." I answered "limited." You are correct that, if the faxed request was to have a check made payable to the customer and have the check mailed to them, it would be "unlimited."

T and D, these are good examples of applying the "convenience" test.

Deena:
Thanks for verifying that.

It seems to me that the original poster would already have a customer disclosure of what is or is not limited that would cover this issue. I do know that disclosures are all over the internet, some better than others.

Thanks, Deena.

The whole "telephonic" thing, as well as the "convenience" test (known around here as the "Reg D = get off your Duff" test), had me thinking faxed transfer request should be included in the "limited" category.

But we had a regional training session a few weeks ago where the trainer (supposedly a Research & Information officer) said they didn't count. He also said we didn't need to do CIP on new loan applications, so that should have been my clue that he didn't know as much as he thought he did....

Thanks guys!

Adds new meaning to the phrase "train the trainer".