I am reading conflicting information. What is the difference?
FRRS: Questions And Answers About Regulation D 2-301.4 (updated 3-94)
Definition and Application
Q1. Are savings accounts subject to ACH debits and credits included in the definition of transaction accounts?
A. Under the definition of “transaction account,” (§204.2(e)(6)) orders received from an automated clearing house (ACH) to debit an account constitute preauthorized transfers. Such an account must be treated as a transaction account unless the deposit contract limits the number of such debits to three per month and it is the practice of the institution to limit such transfers to no more than three. If credits only may be made to the account, then it is not a transaction account, regardless of the number of credits made per month.
OCC Guide on Depository Services 9-96
Appendix Question 4: Verify that transactions are correctly categorized according to the following list:
* Three-transaction limit. Point-of-sale transactions with either ATM or credit card company debit cards and withdrawals payable to third parties initiated by checks or drafts.
* Six-transaction limit. Preauthorized transfers through ACH or EFT; automatic transfers for overdraft protection; telephone, fax, and computer transactions to transfer funds to another account at the same institution; transfers between a parent’s account and a child’s account; and withdrawals initiated by telephone where the proceeds are paid to third parties.
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