When a customer violates Reg D for the third time, we take away whatever was abused; such as internet transfers, ACH etc. Can we give what we took away
back to the customer or is it gone for good, or do we not take away something and just close the account? I'm not sure what is a best practice.
Does Reg D apply to a savings account that has been used as security for a loan?
Can a corporation sweep from a personal account? We say no but are checking what you think?
I have been setting up overdraft transfers for funds trying to pull from savings for ACH transactions. They have funds in their checking, and when I set it up and then repost occurs, the funds are transferred from checking along with a transfer fee. Do you know if I am breaking any rules? Normally I would be transferring funds manually. Or should we just be returning the items.
For Reg D excessive transfers purposes from savings account, can a bank choose to use calendar month for one customer and statement cycle for another customer when both have the same account type, such as a money market deposit, so long as we use this consistently per customer?
Is Popmoney considered an automatic transfer with regards to Reg D (excessive withdrawals) limitations?
If I customer has exceeded Reg D limits on a Money Market account 3 times within the past 12 months, and the account has been changed to a regular DDA, can they open a new Money Market DDA with a different account number?
Can we offer a Money Market account, but restrict withdrawals to face to face transactions or transfer to another account within our bank? That would mean no access to withdrawals by check, ACH or debit card.
How do I find out more specifics about the ATS (Auto Transfer Savings) accounts and regulatory requirements?
Our savings statements are generated every quarter. We recently converted our banking core, and our new core is counting Reg D transactions for every 90 days instead of 30/31 days. My question is, per Reg D, should the customers be allowed 6 transactions per 30 days or 90?