Thread Options Tools
#1187 - 04/04/01 04:08 AM Regulation D
Anonymous
Unregistered

Can anyone tell me how online transfers from a savings or money market account, into a demand deposit account, are viewed under Reg. D? It seems like something just came out about this, but I cant remember where I saw it. I dont normally do Operations, but I was asked about it yesterday.

Are online transfers considered the same as a telephone transfer, or is it considered the same as going into the branch?

I appreciate any help.


Return to Top
General Discussion
#1188 - 04/04/01 04:24 AM Re: Regulation D
A D Virr Offline
Gold Star
Joined: Oct 2000
Posts: 398
Derry, NH
I haven't seen anything specific that would exclude online transfers to demand deposit accounts or to third parties from savings from the limitations. Reg D 204.2(d)(2)says...by means of..telephonic agreement (including data transmission). If someone has some additional information to contribute I too would be interested in knowing.


This is my opinion and not that of my employer.

_________________________
Allan D. Virr, CRCM,CRP
Compliance Audit Solutions, LLC

Return to Top
#1189 - 04/03/01 06:17 PM Re: Regulation D
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
You are right on the mark, A.D. Telephone includes FAX, voice calls, voice mail instructions, home banking (PC or Web based), and anything else that uses telephony (except ATM transactions).


------------------
John Burnett
Cape Cod Bank and Trust Co., N.A.
jsburnett@ccbt.com

[This message has been edited by John Burnett (edited 04-03-2001).]

_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1190 - 04/03/01 07:55 PM Re: Regulation D
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,485
On the Net
Recent news on this which you may have seen could be the bills to increase the number of transfers to 24. That was due for a vote today, but I haven't heard anything yet and it won't take effect immediately. It is combined with an allowance to pay interest on reserves. Some or all of the bill has a phase in over a number of years.

------------------
Andy Zavoina
Opinions stated are not necessarily that of my employer.

_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#1191 - 04/03/01 08:57 PM Re: Regulation D
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Whew! John - I had to re-read your post because I thought it first read as anything else that uses telepATHY -

- and I thought - Good Lord! Are they adding THAT to my job description????

_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1192 - 04/03/01 09:29 PM Re: Regulation D
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
Message removed by author. See later comment below.

[This message has been edited by John Burnett (edited 04-23-2001).]

_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1193 - 04/04/01 01:30 PM Re: Regulation D
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,485
On the Net
From today's ABA NewsBytes:

HOUSE PASSES SWEEP BILL
The House passed a bill (H.R. 974) by voice vote yesterday that would authorize a new 24-transaction sweep account and end the prohibition on paying interest on corporate checking two years after its enactment. The legislation also would allow the Federal Reserve to pay interest on bank reserve balances and gives the agency flexibility on setting reserve requirements.

------------------
Andy Zavoina
Opinions stated are not necessarily that of my employer.

_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#1194 - 04/04/01 09:59 PM Re: Regulation D
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
After carefully reading HR 974, I realized that Section 2 of the bill (effective 2 years from enactment) eliminates the decades-old prohibition on payment of interest on DDA accounts.

Section 3 of the bill permits the 24 transfer per month interest-bearing account (presumably this is really only interesting during the 2-year delay for section 2 effective date). But the account (the "sending" account) will be a transaction account --

quote:
Nothing in this subsection shall be construed to prevent an account offered pursuant to this subsection from being considered a transaction account (as defined in section 19(b) of the Federal Reserve Act for purposes of such Act).

I read this to say that we'd be able to allow daily sweeps from an interest-bearing account (other than an MMDA or savings account) into a business checking account without that being considered payment of interest on the checking account. But because this account could be defined by the Fed as a transaction account, it looks like this legislation will do nothing to eliminate the dastardly 6/3 transfer limits on MMDA/Savings accounts.

[This message has been edited by John Burnett (edited 04-23-2001).]

_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1195 - 04/05/01 05:23 PM Re: Regulation D
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
John,
Perhaps this is the point where the telePATHY would be useful?
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1196 - 04/09/01 08:58 PM Re: Regulation D
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
Bonnie -- yes we need telepathy NOW!

I really don't care -- just pass something so that we don't have to monitor MMDAs like we do now!

Just think how nice it will be to not have to send letters and reminders and then have to explain to examiners your reasoning for doing what you did.

I'm looking forward to this change. I hope it passes!

Dolly Nugent
Vice President
Compliance & CRA Officer
Citizens Business Bank

Opinions are my own and not those of my employer.

_________________________
Dolly Nugent
CRCM
Opinions expressed are my own.

Return to Top
#1197 - 04/09/01 11:58 PM Re: Regulation D
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
Removed

[This message has been edited by John Burnett (edited 04-12-2001).]

_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1198 - 04/25/01 08:47 PM Re: Regulation D
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
I was reading John's post again. If H.R. 974 or S. 229 do not give us the ability to sweep from MMDAs, then what is all the excitement about?

I guess I am confused. If Section 2 permits us to pay interest on business checking accounts 2 years from enactment of the bill and Section 3 allows 24 sweeps in the interim period -- then what are we sweeping from?

Dolly Nugent
VP/Compliance Officer
Citizens Business Bank

_________________________
Dolly Nugent
CRCM
Opinions expressed are my own.

Return to Top
#1199 - 04/26/01 10:03 PM Re: Regulation D
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
We would be sweeping from an interest-bearing transaction account that is not a NOW account. Depending on how the Fed defines the account (assuming they weigh in on this), we might be targeting only our business customers with this. It (along with interest on business checking later) may take off the pressure for repo sweeps, etc. But I don't really see this as being a panacea for our MMDA-aches!
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1200 - 10/04/02 09:50 PM Re: Regulation D
Anonymous
Unregistered

did this house bill ever pass the senate? anything new on this?

Return to Top
#1201 - 10/04/02 09:50 PM Re: Regulation D
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,485
On the Net
No.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top