Reg D limits the number of third-party checks to no more than three per statement cycle or four-week period. The institution is required to either prevent or adopt procedures to monitor after the fact and notify customers who exceed the limits on more than an occasional basis. Our system will generate a notice for each check in excess of three for the statement cycle. In other words, if a customer has five checks clear their account in one statement cycle, our system will generate two notices. In addition, the year-to-date counter will show 2 times exceeded. Would it not suffice to have one notice per statement and therefore, the system would show 1 time exceeded year-to-date? Our software provider is unwilling to modify their system unless we can provide some sort of proof that would back this method up. I would appreciate any guidance you can provide. Thanks!