With the changes to Reg Q I have a question about existing NOW accounts. If we want to start paying interest on a Commercial Account on July 21st these accounts will not be considered a NOW account (no 7 day withdrawal requirement) but will be a Demand Deposit account for Call Report and FR2900 reporting. Could we move all our existing business NOW accounts over to the new interest bearing Commercial checking account type if we give them a notice of change of the 7 day withdrawal requirement? We are trying to keep all our interest bearing business accounts together in one checking account type. Any advise would be appreciated.Thanks!

We are also planning on moving NOW accounts into DDAs. Did you get any information on your process??

Did you get an answer on this question? I am wondering if new account agreements would be needed, any thoughts?

From the Commentary to Regulation DD:

Institutions need not disclose reservations of right to require notices for withdrawals from accounts required by federal or state law.


If you did not disclose the restriction, the change is in the customer's favor and there's no real argument that you need to disclose the fact that it has been eliminated.

Focusing only on the conversion of interest bearing NOW's to interest bearing DDAs, in general the call report issues you mention are paramount. Review your NOW account disclosures line by line to make certain that's the case in your institution. Ironically, if you have gratuitously referred to the account as a "NOW" account, you might want to tell the customer what the new name is, but heaven help you if you attempt to explain why.