Three questions. Need to find guidance for the following ASAP.
Can escrow accounts be NOW accounts?
In a ILB Can internal accounts like a checking account set up for Official checks be just a checking account?
Corporations cannot have a NOW account. Is there any way we can get around this?

1- generally, yes.
2- ?
3- not unless they are not-for-profit.

3 - If the corporation is holding funds in a fiduciary capacity, and the beneficial owners of the funds are all eligible for direct ownership of a NOW account, the corporation may keep those funds only in a NOW account.

Just had a related question directed to me and I would like verification on my answer. We have a lawyers trust account that has been established as a money market account and is having Reg D issues. Since it is a lawyers trust we could change the product to a NOW account correct? And also are lawyers trust accounts exempt from Reg D?

Lawyers could have more than 1 trust accounts. The comingled account (in CA) earns interest paid to the State Bar which is a non-profit and is qualified for a NOW account.

A lawyer can also have a trust account where the interest goes to the client. If the client is eligible (i.e. an individual), then the account is eligible. However, the client could be a corporation and not eligible.

Al

Colorado has lawyers trust accounts and the interest is paid to the State Bar. We have these accounts in money market accounts - are they exempt from Reg D?

We have these accounts in money market accounts - are they exempt from Reg D?

No.

Money market deposit and savings accounts as defined in Regulation D section 204.2(d) don't get around the transaction limits, no matter who holds the accounts.