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#1798214 - 03/25/13 08:51 PM Reg D. - Debit Due to Bank System Workflow?
FlyinHawaiian Offline
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Joined: Jul 2011
Posts: 12
We are a commercial, non-retail bank.

We are designing a new product that will involve an omnibus custodial MMDA tied to a DDA. For operational reasons, we require the accrued interest from the MMDA to be paid to the DDA; this is possible with our deposit system (Systematics). However, our deposit system cannot accommodate the business workflow of having the MMDA interest post to a DDA without having the interest first post to the MMDA and then transferred to the DDA.

My question is if we should consider the debit of interest from the MMDA to the DDA as a limited transaction or not? The position I am taking is that it would NOT be limited, as this is mandated by my bank and our system limitations and not customer-requested.

I had our Compliance Office look into this and they were unable to find language in the Reg that give clear guidance. I'm hoping to get the opinions of others who may have had to deal with this type of issue. Thanks!

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Operations Compliance
#1798303 - 03/26/13 02:44 PM Re: Reg D. - Debit Due to Bank System Workflow? FlyinHawaiian
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I would not include this transfer in the limited transaction total since it is not initiated by the customer.
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