Jane Doe has an IRA account with us. We do not allow customers to set up IRA withdrawals to third parties. We do allow customers to sign an authorization making recurring debits from the IRA account to a checking account which gets a monthly statement. We want to keep the IRS on a quarterly basis for statements. We think we can as the customer is notified of the transaction through the checking account with us but we want to make sure. Comments?

It seems to me based on 1005.9(c)(2) you are correct. But I'm no guru

Intra-institutional transfers. For an electronic fund transfer initiated by the consumer between two accounts of the consumer in the same institution, documenting the transfer on a periodic statement for one of the two accounts satisfies the periodic statement requirement.

Confirmed

Great and thanks. Getting closer to the fine print of this regulation.