We have customers who have thier payroll checks depostied to passbook savings account. There was an error with payroll and and a reversal was sent through. Is this ACH debit going to cause us to be out of compliance?
No. A reversal of a credit is not counted as a third party transfer for the purposes of Regulation D's transaction limits.
The reversal of a direct deposit does not trigger a Regulation E statement requirement for a passbook account, either. See http://www.bankersonline.com/regs/205/regecomm.html Comment 9(c)(1)-2 to Regulation E.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8