If a customer is out of town and calls into the bank and speaks with a CSR and asks the CSR to transfer funds from his savings to his checking account, and the CSR uses the deposit system to manually make this transfer, is this considered an electronic transfer and limited or would this be considered a regular telephone transfer and unlimited? Just a little fuzzy on this one. Thanks!

It would be limited:

Preauthorized transfers from a money market account are limited to six per month, no more than three of which may be by check, draft, debit card or similar order to third parties.

Six per month limits include:

ACH debits for overdraft protection and for payments to a loan at another institution

Transfers from a savings account at the telephoned request of the customer made directly to a bank employee or indirectly through a voice-response system.


Three per month limits include:

Checks payable to third parties

This would fall into the "limited to six" category.

What about internet transfers on the banks website? Does that count as one of the six or is it unlimited?

OK, now I'm confused as well. According to the way I read it, an internet banking transfer counts if it's a request to transfer funds. With our IB system, the customer actually initiates the transfer in the system, they don't actually request anything, they just do it, like at an ATM. I guess I'm reading too much into this, but could it be argued either way?

Internet transfers are account to account or to third parties. ATMs are like writing a check to cash, no third party and no sweeping from an interest bearing account to a non-IBA to get around transaction limitations.

Help, I'm getting confused. If a bank customer writes a check to another bank customer (say I write a check from my money market to the grocery store) and the grocery store "deposits" that check into their account at my bank, is this considered a "transfer" and count toward the 3 checks I can write from my account?

No, it is not considered a transfer, that particular item would be one of the three checks per month limit.

Here's one more I came across. Electronic check (where you write a paper check) - ACH counted toward 6 or check limited to 3? Thanks!

There is another thread on the electronic check topic under the General Discusssion forum.

I thought I was finished with this, but we had one more question. Customer writes check on money market on our bank made payable to herself. She deposits the check at an account she has at another bank. Does this count toward the 3 or would this be unlimited?

It counts - all inclearing checks count, no exception.

Just to verify, "inclearing" would include a check from the MMDA made payable to the same bank for a loan payment? Transfers for loan payments at the same bank are unlimited, but this check would count toward the 3? Thank you.

An "inclearing" check is a check that is received from another bank through the FRB and cleared to your bank for posting, so all inclearing checks are drawn on your bank, payable to a third party or even your customer. They all count as checks - limit 3.

Of course, customers can write a check in person to transfer funds in your lobby, for example, and that check does not go anywhere, except to be posted to the customer account - does not count at all - but it better be appropriately tran coded to assure that it does not appear to be an inclearing check on your records.

T, where is your support for identifying any inclearing item as subject to the 3-transaction limit? The applicable section of the definition reads:

"and no more than three of the six such transfers may be made by check, draft, debit card, or similar order made by the depositor and payable to third parties."

If payable to the depositor, that is not a third party, even if deposited at another institution.

Quote:

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Customer writes check on money market on our bank made payable to herself. She deposits the check at an account she has at another bank. Does this count toward the 3 or would this be unlimited?

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I disagree that this would be limited to three. Since the check is not written to a third party, it's not limited. It's hard to identify these check with our automated processing, however, so most banks probably count all checks toward the three, regardless of to whom they are written.