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#659681 - 01/02/07 04:12 PM what month/period to count for Reg D?
Phoenix Offline
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Phoenix
Joined: May 2003
Posts: 832
southeast
Check written one month, not processed/cashed or deposited until next month. Which month do we count the check toward the Reg. D limitations - when it was written or when it was processed?

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#659690 - 01/02/07 04:19 PM Re: what month/period to count for Reg D? Phoenix
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
You count when it clears not when it is dated.
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#659709 - 01/02/07 04:31 PM Re: what month/period to count for Reg D? Phoenix
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
This is one of the few questions about the transfer limits in Regulation D that are actually answered in the regulation itself. In footnote 4, which provides the basis for ex post transfer monitoring as one of two methods that can be used to ensure compliance with the limits. In that footnote, we find:
Quote:
For accounts described in section 204.2(d)(2), the institution at its option may use, on a consistent basis, either the date on the check, draft, or similar item, or the date the item is paid in applying the limits imposed by that section.


Selecting the date on checks may provide a less controversial option for your customers, but will increase your manual effort in monitoring. Whenever you see an account on an "excessive transfers report," you will need to go back to account records to research check history and determine how many checks were written in the month in question.
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