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#1278270 - 11/02/09 03:27 PM ACH Debit to Passbook Accounts
reknab Offline
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Joined: Oct 2008
Posts: 282
not where I want to be
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?

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eBanking / Technology
#1278374 - 11/02/09 05:12 PM Re: ACH Debit to Passbook Accounts reknab
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
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
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#1278386 - 11/02/09 05:30 PM Re: ACH Debit to Passbook Accounts John Burnett
reknab Offline
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Joined: Oct 2008
Posts: 282
not where I want to be
Thanks John!

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