Skip to content
BOL Conferences
Thread Options
#736519 - 05/18/07 09:54 PM Reg D-Excessive Transactions
Newbie06 Offline
Platinum Poster
Joined: Mar 2006
Posts: 738
I heard some people say that a tranfer to cover a overdraft (not affiliated with an overdraft protection program) is considered a preauthorized transfer. We have all along considered this as a sweep debit and gave customers unlimited transactions for this type. Would this be correct thinking?

Return to Top
Deposits and Payments
#736581 - 05/18/07 11:50 PM Re: Reg D-Excessive Transactions Newbie06
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
I heard some people say that a tranfer to cover a overdraft (not affiliated with an overdraft protection program) is considered a preauthorized transfer.


You heard correctly. The seventh transfer in the calendar month or statement cycle (of approximately the same length) would be a violation. Some internal transfers do not count as EFTs under Regulation E - one of your predecessors may have gotten the concepts confused.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#736592 - 05/19/07 03:02 PM Re: Reg D-Excessive Transactions Elwood P. Dowd
Newbie06 Offline
Platinum Poster
Joined: Mar 2006
Posts: 738
So, really you are saying that the other person may have confused the Regs? Because Reg E covers EFT's and this sweep debit really doesn't fall into that category. I went and looked at Reg E 205.3 and could see how it might be confused. So, the sweep debit to cover a preauthorized transfer (not related to a ODP) does count?

Return to Top
#736594 - 05/19/07 04:42 PM Re: Reg D-Excessive Transactions Newbie06
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If you are sweeping from a savings or MMDA account to cover overdrafts in an account, yes those transfers are limited to six per month.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  John Burnett