After reviewing a few 'excessive withdrawal' reports for our MMDAs and other types of savings accounts, the numbers just didn't look right. I examined a few customer accounts in detail and it appeared that the number of transactions being reported seemed too large.

I inquired of the vendor who advised that the report selection is as follos (sorry for the length):

I looked over the reports and the Christmas Club, Regular Savings and Golden Savings use the same critieria.

Statement Cycles for Christmas Club = annually, Regular Savings = semiannual and Golden Savings = quarterly.

Number of debits is the total number of debits (trancodes 52 – 99) for that statement cycle.
Number of Phone Transactions is the total number of trancode 53 for that statement cycle.
Number of ATM Transactions is the total number of trancode 74 for that statement cycle.
Number of ACH Transactions is the total number of trancode 76 for that statement cycle.
Number of Internet Transactions is the total number of trancode 52 for that statement cycle.
Number of Cash Withdrawals is the total number of trancode 90 for that statement cycle.
Number of Auto Transfer Transactions is the total number of trancode 82 for that statement cycle.
Number of Service Charge Transactions is the total number of trancode 55 for that statement cycle.
Number of Forced Transactions is the total numbe r of tran code 70 for that statement cycle.

Money Market criteria is as follows…

Statement Cycle for Money Market = monthly.

Number of debits is the total number of debits (trancode s 52 – 99 ) for that statement cycle.
Number of Phone Transactions is the total number of trancode 53 for that statement cycle.
Number of ATM Transactions is the total number of trancode 74 for that statement cycle.
Number of ACH Transactions is the total number of trancode 76 for that statement cycle.
Number of Internet Transactions is the total number of trancode 52 for that statement cycle


It appears that the MMDA report is the only one that I can rely on because it reports the numbers on a monthly basis. Am I correct in presuming that I've got to get the vendor to re-program the other reports so that the numbers are reported on a monthly basis so that I can determine if they are excessive in light of the regulation?

Thanks, Doug

As a clarification, we do send the other savings account customers a monthly statement if they have an eligible Reg E transaction during that month, but the numbers on the reports are taken from the 'statement cycle' period.

What core system do you use?

TRINISYS by eBank Systems, Inc.

Yes, I haven't worked with that system but I would think they should be able to set it so that numbers are reported on a monthly basis. Maybe you can get in contact with others that use that system to see how they are setup.

What is bothering me most is that I am not sure I'm interpreting the regulation correctly. It uses the language "during any month or statement cycle of at least four weeks". I'm not sure if that means that for the accounts with a quarterly, semi-annual or annual statement cycle that we HAVE to use the number of transaction within that statement cycle (which might lead to a number of 'violations')or if we have the option of basing it on a calendar month.

You have the option of tracking it on a calendar month basis or you can set up a "item counting cycle" that is at least four weeks long. So if you have savings accounts that are statemented on the 15th of every third month, you can run your item counting from the 15th of each month to the 15th of the next.

Thanks, John. I was hoping that we had that monthly option.