If a bank needs to convert an account from a money market account to an account that allows unlimited transactions - can this be done without new disclosures / signature cards? Bascially the customer is violating Reg D transaction limits but will not come in to change the type of account. Can the bank just change the type of account on their own?

Without new disclosures? - No

Without a new signature card? - that all depends on what you signature does for you. It is more of a legal question than a compliance issue.

Thanks - that's what I thought. The big banks charge fees for going over the transaction limits but our bank doesn't want to do that.

Charge or not, it makes no difference in enforcing the rule.

I know little banks that charge but as Randy said, that has nothing to do with regulatory compliance. I worry about whether the statement regarding the fees makes it appear that exceeding the limit is okay as long as the fee is paid.