Unfortunately, today's article on Regulation D leaves the impression that assessing substantial fees on customers who exceed transaction limits will be enough to satisfy examiners. Such is not the case.
FRB opinion has been that the existence of fees just increases the cost of customer non-compliance, and customers willing to accept the cost can break the rules.
Better to couple fees with the standard monitoring (monthly and daily) and follow-up, shutting down problem accounts.
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John Burnett
Cape Cod Bank and Trust
[This message has been edited by John Burnett (edited 10-27-2000).]