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#2194703 - 10/04/18 04:53 PM MMDAs-Subject to Funds Availability?
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,137
In the mountains
Since a MMDA is a savings account - it is not subject to Reg CC Funds Availability disclosure and hold rules correct?

Thanks in advance.
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#2194730 - 10/04/18 06:55 PM Re: MMDAs-Subject to Funds Availability? Likes to Comply
burkemi Offline
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Joined: Nov 2013
Posts: 552
Correct. MMDAs are governed by Reg D.

(2) The term “savings deposit” also means: A deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or as a money market deposit account (MMDA),
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#2194731 - 10/04/18 06:57 PM Re: MMDAs-Subject to Funds Availability? Likes to Comply
mtngrrl Offline
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mtngrrl
Joined: Mar 2011
Posts: 503
Northern California
Check your state laws, however. In California, savings accounts are subject to state funds availability laws.
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#2194754 - 10/04/18 08:14 PM Re: MMDAs-Subject to Funds Availability? Likes to Comply
burkemi Offline
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Joined: Nov 2013
Posts: 552
Interesting. Out of curiosity, how do deposit-secured loans work? I assume there are exceptions to account for it?
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#2194757 - 10/04/18 08:19 PM Re: MMDAs-Subject to Funds Availability? Likes to Comply
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Collateral holds are not subject to Reg CC.
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#2194769 - 10/04/18 08:32 PM Re: MMDAs-Subject to Funds Availability? Likes to Comply
burkemi Offline
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Joined: Nov 2013
Posts: 552
I am referring to the reference of savings accounts in California, and am genuinely curious. (Of course, if that's what you're meaning, then thank you.....and then I feel like a dummy. Hehe.)
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#2194948 - 10/09/18 03:40 PM Re: MMDAs-Subject to Funds Availability? Likes to Comply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Not a dummy at all!

Massachusetts, like California, pulls savings account under the Reg CC tentflaps, and bankers here have to make funds in regulator savings and MMDA accounts available just as they would if the funds were in a transaction account. CD accounts aren't affected.

But, a collateral hold on all or a portion of an account balance isn't affected by Reg CC. It takes precedence, as would a hold on funds in response to an IRS levy or other legal attachment of the funds.
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