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