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#131342 - 11/17/03 08:28 PM Reg D Six per month rule
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Considering Reg D,is the following correct?

ACH is limited to 6 per month. Three per month involves POS (involves a 3rd party) and checks & drafts to 3rd parties. (according to Reg D) Reg D says "no more than 3 of the 6 such transfers may be made by check, draft, debit card, or similar order made by the depositor and payable to 3rd parties". So you could have 6 ACH per month/stmt cycle, but in a month where there is a debit card transaction, you could only have 5. (5 ACH + 1 debit card trans = 6 transfer limit)
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General Discussion
#131343 - 11/17/03 08:34 PM Re: Reg D Six per month rule
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
Sounds as if you are on the right track. Be sure to verify your system trancode parameters to make sure they are tracking correctly.

Examples:
3 POS + 1 telephone transfer request + 2 ACHs = 6
2 ACHs + 2 checks + 12 ATM withdrawals = 4
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#131344 - 11/17/03 08:36 PM Re: Reg D Six per month rule
incandescent Offline
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incandescent
Joined: Oct 2003
Posts: 125
Your statement rings true to me, basically acknowledges that a total of six transactions are possible - six ACH, for example. But, when third party transactions come into play, only 3 of those are possible - cutting the ACH to 3, to stay within the overall 6 total.

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#131345 - 11/18/03 12:06 AM Re: Reg D Six per month rule
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Someone might help me with this - is it 6 w/d per month, or per statement cycle?
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#131346 - 11/18/03 02:41 AM Re: Reg D Six per month rule
Andy_Z Offline
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Yes. 204.2(d)(2) ...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...
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#131347 - 11/18/03 04:11 PM Re: Reg D Six per month rule
John Burnett Offline
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John Burnett
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Cape Cod
Read the emphasized part of Andy's quote CAREFULLY. Don't think that you can multiply the number of allowed transfers if you expand your statement period to quarterly.
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