I am preforming a Reg D audit and believe I need further proof of the 12 month rolling guidance.I have found on BOL Guru question that it is best practice to follow the 12-month rolling period in regards to three time limits. Can someone direct me to where I can find that in the commentary? I have searched with no luck.

This thread may be of interest:

Excessive Withdrawals

Thanks Doug:

Quick question I see you answered with your procedures do you follow the 12 month rolling or some other time frame?

I follow the 12 month rolling. First time in a rolling 12-month, you get the 'advisory' letter; second time you get the 'warning' letter, third time you get the letter that says we're closing/transferring your account unless you give me other instructions.

I've only had to send the third letter twice (and I've closed the account and transferred the funds to their DDA account).

Thanks for clarify it!