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#1860812 - 10/11/13 03:03 PM Reg D
amberleigh Offline
Junior Member
Joined: May 2011
Posts: 34
Kansas
Are banks required to have a Reg D Policy? We subscribe to sample policies from Sheshunoff, but Reg D isn't included.

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#1861079 - 10/11/13 07:25 PM Re: Reg D amberleigh
renniks Offline
Diamond Poster
renniks
Joined: Sep 2003
Posts: 2,162
New England
I don't believe you are required. My bank has 52 different policies, but we do not have one for Reg. D.

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#1861107 - 10/11/13 07:54 PM Re: Reg D amberleigh
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
You need to have a procedure to identify accounts in which the accountholders fail to observe the monthly transaction limits more than occasionally, and to take appropriate action to curb excessive activity in those accounts. Policy? No.
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#1861162 - 10/11/13 08:38 PM Re: Reg D amberleigh
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
I agree with John Burnett... a procedure is more than adequate.
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#1884756 - 01/09/14 07:35 PM Re: Reg D John Burnett
HuntFish Offline
Member
Joined: Jan 2010
Posts: 63
undecided
I see that you stated "montly" monitoring. Currenlty this is the way that we monitor savings and excessive transactions:
the savings statement will be quarterly, so the montoring is quarterly (allowing only 6 transfers/withdrawals per quarter). If the savings statement is montly (due to EFT - Reg E), then the monitoring is monthly (allowing only 6 transfer/withdrawal per month). Something in the way that said "monthly" makes me think that we need to re-do our monitoring and review each savings account monthly for excessive transactions and forget the quarterly monitoring. Ami I right???

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#1885677 - 01/11/14 04:34 PM Re: Reg D amberleigh
HuntFish Offline
Member
Joined: Jan 2010
Posts: 63
undecided
Bump....but i think i know my answer!

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#1886113 - 01/13/14 09:03 PM Re: Reg D amberleigh
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
Yes. The rule says you have to control activity so that restricted transfers or withdrawals from the savings account don't exceed six in (a) a calendar month, or (b) a statement cycle or similar period of at least four weeks.

If you cycle accounts on a mid-month to mid-month basis, you clearly can use the statement cycle and it will be at least four weeks long.

If you cycle on longer than a monthly basis, as for a quarterly savings account, you can use the longer statement period, but you'd be restricting your customers unnecessarily to 6 limited transactions per quarter. Instead, you should be cutting that three-month period into three parts and monitoring on a basis of a basis of more-or-less 4-week periods (from the 20th of one month to the 20th of the next, as an example).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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