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#643983 - 11/29/06 04:30 PM Reg D - Limitation of transactions
LoveHMDA Offline
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Joined: Nov 2005
Posts: 283
We are implementing procedures to allow our customers to transfer (or sweep) funds from one of their "debited" accounts to a "credited" account. Our procedures call for the customer to sign an authorization form directing the amount of funds to be transferred and from/to which accounts. My question is, does this transfer, or "sweeping" count toward the 6 or 3 limit? Thanks in advance for your response!!

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#644006 - 11/29/06 04:45 PM Re: Reg D - Limitation of transactions LoveHMDA
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
How are the transfers going to be conducted? If customer is initiating the transfer electronically, it is likely going to fall under the preauthorized limit of six.
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#644016 - 11/29/06 04:57 PM Re: Reg D - Limitation of transactions BrendaC
LoveHMDA Offline
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Joined: Nov 2005
Posts: 283
I'm sorry, the customer will fill out the authorization form and the transfer will be triggered based on the balance of the account, therefore, the bank's software will automatically conduct the transfer per the customer's authorization forms accounts and amounts. I apologize if I'm not describing this real clear!! I was thinking it would fall under the 6 as well. Am I wrong in thinking that the limit of 3 pertains mostly to transfers to third parties?

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#644070 - 11/29/06 05:29 PM Re: Reg D - Limitation of transactions LoveHMDA
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
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On the Net
If your customers are eligible for an ATS account, you won't have any limits if you properly classify them.
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