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#12354 - 06/12/01 06:18 PM Reg. D Limits and ACH Transfers
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,542
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The new devices gaining popularity with merchants allow a paper check to be converted to an ACH and debited automatically from the consumer's deposit account.

Has anyone found any MMDA abuses with these as to third party transfers? While I wouldn't anticipate MMDA customers doing this frequently, I can see that it will require additional work as we monitor on an ex post basis. My systems people tell me initially that while we can stop POS transfers in several ways, this is different.

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

My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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eBanking / Technology
#12355 - 06/18/01 12:50 PM Re: Reg. D Limits and ACH Transfers
OkieOps Offline
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Joined: May 2001
Posts: 752
I have not yet seen any MMDA abuses with the new check processing system. These items do clear as an ACH transaction. This is different from a POS transaction. They can be returned, a stop pay can be placed, etc. If I have a MMDA customer who exceeds the transaction limitation, they will get a letter because they did in fact write more than 3 checks.

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#12356 - 06/19/01 12:54 PM Re: Reg. D Limits and ACH Transfers
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,786
Cape Cod
I think that one of the real challenges we face is the correct handling of these ACH alternatives to checks. In many systems, all ACH items receive the same processing transaction code. But some ACH items qualify for the 6/month limits in Reg. D, and others -- those that replace checks -- arguably should add to the "3 bucket" as well.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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