Skip to content
BOL Conferences
Page 5 of 6 1 2 3 4 5 6
Thread Options
#2236403 - 05/08/20 05:17 PM Re: Reg D Excessive Transfers Bankwoman1
rainman Offline
Power Poster
rainman
Joined: Nov 2004
Posts: 3,242
Well put.
_________________________
Nobody's perfect, not even a perfect stranger.

Return to Top
Deposits and Payments
#2236404 - 05/08/20 05:20 PM Re: Reg D Excessive Transfers Adam Witmer
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
Adam....thank you so much for this explanation!!!

The light is on a dimmer switch and slowing coming on..... blush

Return to Top
#2236463 - 05/11/20 02:32 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You will be getting some Call Report revisions that will have to be made due to the Fed's definition changes for savings deposits and transaction accounts. They should be coming out by June. The most likely changes will be in the instructions, rather than the Call Report itself. Whether you will have the flexibility to report savings deposits as transaction accounts or not will depend on what the FFIEC says, not the Fed's loose instructions for the FR 2900.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2236464 - 05/11/20 02:35 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I'll be presenting a special ONE-HOUR webinar on the Fed's elimination of savings deposit transfer and withdrawal limitations at 2:30 ET on Monday, May 18. Register now for Limits on Savings Account Transfers -- An Update.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2236600 - 05/12/20 11:13 PM Re: Reg D Excessive Transfers John Burnett
Saintsfan Offline
Member
Joined: Apr 2014
Posts: 93
Any problem with keeping the savings and MMKT Account "as is" but just stop sending letters and closing accounts if the disclosed withdrawal limits are exceeded?

Return to Top
#2236601 - 05/12/20 11:45 PM Re: Reg D Excessive Transfers Bankwoman1
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,628
Galveston, TX
No.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2236605 - 05/13/20 12:37 PM Re: Reg D Excessive Transfers Bankwoman1
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,663
I agree with Randy and to me, it seems like that really was the point of the rule - to allow you to just stop monitoring and enforcing withdrawal limits without changing anything else.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2236666 - 05/14/20 12:32 PM Re: Reg D Excessive Transfers Bankwoman1
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,663
FYI - The Federal Reserve updated their FAQs yesterday to clarify what I explained previously: that savings deposits are still not subject to Reg CC holds.

https://www.federalreserve.gov/supervisionreg/savings-deposits-frequently-asked-questions.htm
13. How did the recent amendments to Reg D impact Reg CC?
On April 24, 2020, the Board of Governors issued an interim final rule amending its Regulation D to delete the six per month limit on convenient transfers from “savings deposits.” Among other things, the interim final rule amended the definition of “transaction account” in 12 CFR 204.2(e) such that the definition now includes accounts described in 204.2(d)(2) (savings deposits).

Regulation CC provides that an “account” subject to Regulation CC includes accounts described in 12 CFR 204.2(e) (transaction accounts) but excludes accounts described in 12 CFR 204.2(d)(2) (savings deposits). Because Regulation CC continues to exclude accounts described in 12 CFR 204.2(d)(2) from the Reg CC “account” definition, the recent amendments to Regulation D did not result in savings deposits or accounts described in 12 CFR 204.2(d)(2) now being covered by Regulation CC.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2236667 - 05/14/20 12:58 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
They've also updated the FAQ to make it clear that they don't intend to return to reserve requirements or to add back regulatory limits on savings deposit transfers/withdrawals.

The Fed could have made matters a lot clearer from the outset if it had made those statements and the statement about Reg CC on April 24, and added "eliminate" or "stop" to their use of "suspend."

The Fed rule writers seem to have forgotten where they left their "banker hats." They used to be better at anticipating some of the questions bankers might have about their rules.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2236887 - 05/19/20 12:36 PM Re: Reg D Excessive Transfers Bankwoman1
Getting_Grayer Offline
100 Club
Joined: Oct 2007
Posts: 194
USA
John-

After attending your webinar yesterday, I noticed in the handout you included a statement that "subaccounts" are now gone. Does this mean we no longer need to provide the subaccount disclosure? Can you elaborate more?

Return to Top
#2236961 - 05/19/20 08:02 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
As we discussed "off-line," sub-accounts aren't really as relevant to the changed definition of savings deposits as they are to the other big Reg D development -- the end of reserve requirements. Subaccounts have been used by many banks to categorize balances as savings deposits (no reserves) when the customer-facing side of the account behaves like a transaction account.

But because there is no longer a reserve requirement, there is no longer a need for subaccounts and if you don't keep them, you don't need the disclosures that go with them.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2237360 - 05/29/20 04:37 PM Re: Reg D Excessive Transfers Bankwoman1
TaraTLR Offline
100 Club
Joined: May 2013
Posts: 144
Can a Bank choose which types of Savings Deposit accounts they want to remove the six withdrawal limits on? For example, can we removed the limit on the standard savings deposit account, but not remove it on the Money Market Accounts?

Return to Top
#2237362 - 05/29/20 04:38 PM Re: Reg D Excessive Transfers Bankwoman1
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,628
Galveston, TX
Of course you can.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2237426 - 06/01/20 05:00 PM Re: Reg D Excessive Transfers John Burnett
banker-12 Offline
Diamond Poster
Joined: May 2007
Posts: 1,243
We stopped the monitoring of excessive transactions and charging an excessive transaction fee to our customers but we have not updated our new account disclosures. We were waiting until the end of the comment period in case they added it back (to avoid doing a change notice). So now that it's clear that the FED has no plans to add back the transfer limitations, we can update the account disclosures. Just want to confirm that it's not coming back

Thanks,

Return to Top
#2237428 - 06/01/20 05:17 PM Re: Reg D Excessive Transfers Bankwoman1
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,628
Galveston, TX
Under current circumstances - no. But like everything else, nothing is permanent.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2241083 - 08/14/20 07:17 PM Re: Reg D Excessive Transfers rlcarey
CRL Offline
Platinum Poster
CRL
Joined: Sep 2003
Posts: 579
Originally Posted by rlcarey
I would just leave everything alone and just quit monitoring and come back and visit this in a year and figure out what you want to do, if anything.


Randy, I'm circling back to this. I'm wondering if most who have eliminated the transaction limit have changed their new account disclosures? We took the "sit on the fence" stance, but think we should change our disclosures now for new accounts to eliminate reference to the 6 transaction limit?

Return to Top
#2241108 - 08/15/20 11:33 AM Re: Reg D Excessive Transfers Bankwoman1
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,223
The West
Not yet. Still waiving fees. We will be looking at this again in October.
_________________________
TryingToComply
CRCM

Return to Top
#2243559 - 10/05/20 08:36 PM Re: Reg D Excessive Transfers Bankwoman1
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
Like CRL we too took the "sit on the fence" stance, we changed nothing and just stopped the back office operation of monitoring for excessive withdrawals....internally we documented that we would do nothing permanent until the final rule came out...

I'm wondering if we should do something permanent....should we change our disclosures to eliminate the reference to the 6 transaction limit....or should we continue to "temporarily suspend"

We also have a Reserve Requirement policy....since there are no longer reserve requirements, should we just delete this policy?

What have others been doing?

Return to Top
#2243560 - 10/05/20 08:50 PM Re: Reg D Excessive Transfers Bankwoman1
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
I should specify we have a Reg D-Reserve Requirement policy......is a Reg D policy still a necessity?

Return to Top
#2243566 - 10/05/20 09:18 PM Re: Reg D Excessive Transfers Bankwoman1
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,746
Illinois
Since the Federal Reserve could change the reserve requirements at its discretion, unless Reg D is repealed, it's probably a good idea to keep that policy.

The Fed made a change to the definitions of Reg D. To reinstitute transaction limitations, the Fed would have to publish a notice in the federal register, have a comment period and set a future compliance date. The Fed addressed the verbiage of "suspend" when it updated the FAQs in May 2020.

https://www.federalreserve.gov/supervisionreg/savings-deposits-frequently-asked-questions.htm

Are the recent amendments to Regulation D temporary or permanent?
On April 24, 2020, the Board of Governors issued an interim final rule amending its Regulation D to delete the six-per-month limit on convenient transfers from "savings deposits." The underlying reason enabling the changes in Regulation D is the FOMC’s choice of monetary policy framework of an ample reserve regime. In such a regime, reserve requirements are not needed. As a result, the distinction made by the transfer limit between reservable and non-reservable accounts is also not necessary. The Committee’s choice of a monetary policy framework is not a short-term choice. The Board does not have plans to re-impose transfer limits but may make adjustments to the definition of savings accounts in response to comments received on the Board’s interim final rule and, in the future, if conditions warrant.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2243595 - 10/06/20 04:14 PM Re: Reg D Excessive Transfers Bankwoman1
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
Thank you Brian....I was aware of the FAQ update....but since it states that they may make adjustments to the definition of savings accounts in response to comments....I'm really hesitant to make any kind of changes until the final rule comes out.....

I am wondering what others have done....if any of you care to share.....

Return to Top
#2243610 - 10/06/20 05:39 PM Re: Reg D Excessive Transfers Bankwoman1
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,223
The West
We too suspended the fees and discontinued monitoring for excessive transactions. We intend to keep the accounts priced as they are with an excessive transaction fee. Similar to any other account with excessive transactions. We will just charge the fee, but we will no longer be sending warning letters.

Will be sending all MMDA/SAV customers a statement message to announce that we have been waiving the fee due to the pandemic, but intend to start assessing again beginning XX/XX/XXX.

Will be revising TISA disclosures to revise the language about converting to another account type.

I've checked other banks websites in our area and so far I have not found any that have changed their pricing.
_________________________
TryingToComply
CRCM

Return to Top
#2243629 - 10/06/20 07:09 PM Re: Reg D Excessive Transfers Bankwoman1
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
We never charged any fees.....we just stopped the entire monitoring process...we don't want to go back to monitoring if we don't have to.....it's labor intensive for us....

I attended a webinar that stated if we totally do away with transaction limitations then at some point we are going to have to classify savings accounts as transaction accounts which we don't want to do....the suggestion made was to limit to 24 transactions....we don't want to do this if it is not necessary to do....

Without a final rule that defines a savings account, are we ok to still not change anything for now?

Have our disclosures still show the 6 limitations and just not enforce it?

Return to Top
#2243630 - 10/06/20 07:14 PM Re: Reg D Excessive Transfers Bankwoman1
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,746
Illinois
Quote
I attended a webinar that stated if we totally do away with transaction limitations then at some point we are going to have to classify savings accounts as transaction accounts


The instructor from that webinar must not have read the FAQs.

How did the recent amendments to Reg D impact Reg CC?
On April 24, 2020, the Board of Governors issued an interim final rule amending its Regulation D to delete the six per month limit on convenient transfers from “savings deposits.” Among other things, the interim final rule amended the definition of “transaction account” in 12 CFR 204.2(e) such that the definition now includes accounts described in 204.2(d)(2) (savings deposits).

Regulation CC provides that an “account” subject to Regulation CC includes accounts described in 12 CFR 204.2(e) (transaction accounts) but excludes accounts described in 12 CFR 204.2(d)(2) (savings deposits). Because Regulation CC continues to exclude accounts described in 12 CFR 204.2(d)(2) from the Reg CC “account” definition, the recent amendments to Regulation D did not result in savings deposits or accounts described in 12 CFR 204.2(d)(2) now being covered by Regulation CC.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2243637 - 10/06/20 07:31 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes, you have the option to sit and wait for a final rule that may clarify the distinction (if any) between a savings deposit and a transaction account. You can leave your disclosures as is if there is any chance you will revert to enforcing the old limits. But I do hope you informed customers that the limits were suspended until further notice.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
Page 5 of 6 1 2 3 4 5 6

Moderator:  John Burnett