Our CEO is thinking of implementing a fee for transactions that exceed the six withdrawals/transfers per statement cycle defined in Reg. D under savings deposit. He wants to do this for all debits that exceed six not just the ones that are covered under the regulation. I am not aware of any regulation that prohibits this but i did state that it may make the bank look bad for charging all these fees. Is there any regulatory burden i am not aware of that would prohibit all these fees from being charged?

We do this and so far have not been scrutinized.

We have this type of fee. Ours is actually more restrictive we charge after 5.

we charge after 6 on MM and 3 on savings.

Agreed. However, don't forget that charging those fees does not relieve you of the responsibility of taking action on those accounts which consistently exceed the limit on covered transactions. The fees may help to curb such excesses, but if they continue you have to take some action.

As long as our customers are happy, that is my main concern. I just don't want our CEO to get carried away and start charging after 1 transaction.

Fees are a banks middle name and it will be worse. Do your competitor banks charge this fee? My bank did forever, but re-read Doug's post above as this is not a substitution for Reg D enforcement.