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#1227151 - 08/04/09 08:04 PM Reg. D Comfusion again
Hockey Rules Offline
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Okay, MMDA and Statement Savings can you please verify with me that the customer can make as many in person withdrawals as they would like via teller window or atm. They also can set up as many internal transfers to another account or loan as they would like??? And for instance our statment savings states all this however we will charge for any in person withdrawals if they make more than two per month. I have had so many questions lately, that I think I have over anayzed this. thanks
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Deposits and Payments
#1227212 - 08/04/09 08:48 PM Re: Reg. D Comfusion again Hockey Rules
Kelsey D Offline
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Ohio
12 CFR § 204.2(d)(2) The term “savings deposit” also means: A deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or as a money market deposit account (MMDA), that otherwise meets the requirements of §204.2(d)(1) and from which, under the terms of the deposit contract or by practice of the depository institution, the depositor is permitted or authorized to make no more than six transfers and withdrawals, or a combination of such transfers and withdrawals, per calendar month or statement cycle (or similar period) of at least four weeks, to another account (including a transaction account) of the depositor at the same institution or to a third party by means of a preauthorized or automatic transfer, or telephonic (including data transmission) agreement, order or instruction, or by check, draft, debit card, or similar order made by the depositor and payable to third parties. A preauthorized transfer includes any arrangement by the depository institution to pay a third party from the account of a depositor upon written or oral instruction (including an order received through an automated clearing house (ACH)) or any arrangement by a depository institution to pay a third party from the account of the depositor at a predetermined time or on a fixed schedule. Such an account is not a transaction account by virtue of an arrangement that permits transfers for the purpose of repaying loans and associated expenses at the same depository institution (as originator or servicer) or that permits transfers of funds from this account to another account of the same depositor at the same institution or permits withdrawals (payments directly to the depositor) from the account when such transfers or withdrawals are made by mail, messenger, automated teller machine, or in person or when such withdrawals are made by telephone (via check mailed to the depositor) regardless of the number of such transfers or withdrawals.

In other words...

Unlimited: deposits of any type, withdrawals in person, by ATM, by mail, or telephone (when check is mailed), and transfers to make loan payments at the same institution

Limited to 6: preauthorized or automatic transfers, telephone transfers, and transfers by check, draft, debit card, or similar order to third parties
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#1227215 - 08/04/09 08:49 PM Re: Reg. D Comfusion again Hockey Rules
rlcarey Online
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Galveston, TX
that the customer can make as many in person withdrawals as they would like via teller window or atm.

That is true

They also can set up as many internal transfers to another account or loan as they would like???

To pay a loan - yes. To another deposit account - no.

And for instance our statment savings states all this however we will charge for any in person withdrawals if they make more than two per month.

That is a contractual issue between the bank and the depositor.
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#1227244 - 08/04/09 09:20 PM Re: Reg. D Comfusion again rlcarey
Still Smiling Offline
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Ok now I am confused. Do loan payments count as unlimited if at you institution or are they included in the 6?
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#1227297 - 08/04/09 10:44 PM Re: Reg. D Comfusion again Still Smiling
rlcarey Online
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Galveston, TX
Transfers for loan payments are excluded from the 6. Transfers to other accounts would be included in the 6 unless in person, mail, etc.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1227300 - 08/04/09 10:48 PM Re: Reg. D Comfusion again rlcarey
Marnie Offline
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Loan payments at your own institution, not other ones.

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#1227515 - 08/05/09 03:24 PM Re: Reg. D Comfusion again Marnie
Still Smiling Offline
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I think I get it...So as long as the transfer is for a loan payment at our bank, it is unlimited, but if it is to a third party it is included in the 6. I can't seem to find this in the regulation, could someone point this out to me?
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#1227526 - 08/05/09 03:31 PM Re: Reg. D Comfusion again Still Smiling
Kelsey D Offline
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Posts: 516
Ohio
It's within the section of Reg D that I quoted earlier.
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#1227555 - 08/05/09 03:52 PM Re: Reg. D Comfusion again Kelsey D
rlcarey Online
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Specifically: "Such an account is not a transaction account by virtue of an arrangement that permits transfers for the purpose of repaying loans and associated expenses at the same depository institution "
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#1227560 - 08/05/09 03:55 PM Re: Reg. D Comfusion again rlcarey
Hockey Rules Offline
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Thanks so much for all your help.
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#1227570 - 08/05/09 04:02 PM Re: Reg. D Comfusion again Hockey Rules
Still Smiling Offline
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Posts: 767
Yes, thank you. It was such a long sentence that I got lost.
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