In our online banking program, customers can go in and in one online banking transaction, take money from one account and split the deposit into multiple accounts. We have a customer that takes money a couple of times a month from her Savings account and splits it between 2 checking accounts, 2 savings accounts and a Christmas Club.

When the system posts this to her savings account, however, it separates the withdrawal into five transactions with a description as to how much went to each account. The customer considers this as making one withdrawal from the savings, but the Reg D system counts it as 5 withdrawals since they post as separate line items.

How do others handle this? Do you think it's acceptable to count them as one transaction and not consider it excessive withdrawals since we can show from the date and time stamp that they were all done at the same time?

IMHO.....those are separate transactions, even though your system allows multiple transfers with one click.

I'm not sure how you could convince an examiner that this was one transactions if it appears on the customer's statement as multiple transactions. My question is why does your system post multiple withdrawals? I would suggest you set the transaction up as a recurring (if possible) with multiple deposits and one withdrawal. That would only show one transaction on the customer's statement and you'd have nothing to explain.