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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