I understand that OD sweeps from a Savings to a DDA are counted in the number of allowable transactions under Reg D. When there is a violation, we can remove ODP or change the account type. If we remove ODP and at a later date, for example 5 months, the customer requests ODP again, is there any type of guidance for allowing/not allowing this? Or is it internal policy? Thanks for any info!

Policy. There's nothing in the regulation. You want your policy to be such that you can maintain control of your Reg D monitoring and enforcement effort, and you'll be judged on the overall performance, rather than on an account here and an account there. If I were writing the policy, I'd keep the reins tight, and permanently cancel the ODP transfer access if the customer runs over the count ceiling at all in the next year.

Thanks John!