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#131342 - 11/17/03 08:28 PM Reg D Six per month rule
ahou Offline
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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)
Opinions are my own and not of my employer.

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#131343 - 11/17/03 08:34 PM Re: Reg D Six per month rule
BrendaC Offline
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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.

3 POS + 1 telephone transfer request + 2 ACHs = 6
2 ACHs + 2 checks + 12 ATM withdrawals = 4
Life without Jesus is like an unsharpened pencil - it has no point.

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#131344 - 11/17/03 08:36 PM Re: Reg D Six per month rule
incandescent Offline
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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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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?
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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

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

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