Are E-Banking Transactions Considered "In Person"?
Answer by Andy Zavoina and John Burnett, BOL Gurus
Question: We are in the process of investigating Internet Banking and would like to know how transactions conducted through this product might impact Reg D transfer limitations. Are transactions done via Internet Banking considered to be "In Person"?
Answer by Andy Zavoina: BIO AND CONTACT INFO
These are more akin to telephonic transactions, they are convenient and generally count as being limited. An exception would be a bill pay where a customer has a check sent to them. Because that would be inconvenient, it would not be limited. Transferring funds from one deposit account to another would be limited as that would be a sweep. It would not be the same as the customer coming to the bank to make a withdrawal and deposit (inconvenient).
Answer by John Burnett: BIO AND CONTACT INFO
Internet banking transfers between a customer's own accounts are subject to Regulation D's 6/month limits. Bill payment transfers to third parties fall under the 3/month rule.
[Editors Note: As of 7/2/09, the separate limit of three per month for checks, POS debit card transactions, etc., has been eliminated, and those transactions are now only subject to the 6/month limit that applies to other restricted transfers and withdrawals.]
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