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#1338123 - 02/05/10 12:27 AM Regulation D Excessive Transactions
Hugapug Offline
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Joined: Jan 2010
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Is redisclosure required after the recent change extending the 3-check limitation to 6? This is a beneficial change so I'm not sure if redisclosure is required or not. I couldn't find redisclosure requirements in the reg itself. Please help.

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Operations Compliance
#1338138 - 02/05/10 03:26 AM Re: Regulation D Excessive Transactions Hugapug
rlcarey Online
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rlcarey
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Galveston, TX
Since it does not fall into this category: "may reduce the annual percentage yield or adversely affect the consumer", the answer would be no.
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#1338353 - 02/05/10 03:16 PM Re: Regulation D Excessive Transactions rlcarey
SunnyFL, CRCM Offline
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Has anyone heard if OTS has followed suit yet?

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#1339370 - 02/08/10 03:34 PM Re: Regulation D Excessive Transactions SunnyFL, CRCM
John Burnett Offline
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Cape Cod
The OTS regulation that mentions the "three per month" limit is one that defines, for the purpose of the OTS regulations, the term "money market deposit account." It doesn't appear to limit savings account transactions as Regulation D does. The problem is, I think, trying to figure out what to call an account on which interest is paid that limits transactions to 6 per month.

And no, OTS hasn't changed the rule yet.
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#1351012 - 03/02/10 04:16 PM Re: Regulation D Excessive Transactions John Burnett
dollars & sense Offline
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Forgive me I am a bit behind. I just encounted that our disclosures still state only three transactions can be by check, draft, or debit card. Did the regulation change to eliminate the three and just keep all electronic type transactions under the six?

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#1351374 - 03/03/10 11:45 AM Re: Regulation D Excessive Transactions dollars & sense
rlcarey Online
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rlcarey
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Galveston, TX
It is now six for all types of preauthorized transactions.
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