If we have not previously been counting Internet withdraws in a MMDA 6 transaction limit and now realize we should be counting those transactions, do we need to notify our MMDA customers in advance, maybe 30 days, of the change prior to beginning to count those transactions?

You don't NEED to, but it's probably a good idea--particularly for those customers who are already over the line. You will want to explain that you are not changing the terms of the account--the account agreement always called for this limitation.

This is a cross post and I replied in the General area. While I think letting them know that the rules will be enforced is good, I would not provide any grace period to comply as that compounds a now known problem. In my mind, that makes it worse. You may choose to be liberal on the current counts from X date back, but that would be it.

I also wouldn't want to indicate internally that there is a problem in the transaction limitations, only that the bank wasn't monitoring them ex-post, as it should have been. The difference is that one way may lead you to believe that accounts were used as DDAs and no one cared. The other is that rules were in place, but not monitored for compliance.

Thanks Richard. That's the approach I want us to take as well. Our account disclosures indicate that "electronic" transactions are limited to six per statement cycle and to me, that includes PC banking transactions. We plan to write a report to ID those accounts and let their officer give them a phone call with a pre-warning.