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#2233323 - 03/19/20 06:59 PM
Reg D Excessive Transfers
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Diamond Poster
Joined: Dec 2015
Posts: 1,113
Midwest
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I had a really good question (at least I thought so) asked to me by one of our branch managers earlier and I'm just not sure how to respond. She was wondering if we were going to continue to penalize people that go over their Reg D transfer limits from their savings account now that many people are self quarantining and not able to get out of their homes. We just closed our lobbies this morning, however, our drive-thrus are open, but many people are not going out at all, especially older people and those with health issues. Should this be something the bank makes a decision on or should we wait and see if there is any kind of regulatory release addressing it? Is anyone else making exceptions for these transfers right now?
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#2233360 - 03/20/20 01:00 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Platinum Poster
Joined: Nov 2013
Posts: 556
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So far there have been no temporary amendments to the Reg, at least not that I'm aware. My advice would be to continue your normal business in this regard since it is driven by regulation. If an amendment is passed and provides a beginning date, you can always go back to that date refund any fees charged. Find other ways to assist your customers that doesn't break regulation, such as temporarily waiving maintenance fees.
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#2233390 - 03/20/20 04:00 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Gold Star
Joined: May 2015
Posts: 296
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The Fed has come out and removed reserve requirements. While this doesn't get rid of the Reg D withdrawal limits, it would allow you the option to convert savings accounts to transaction accounts with no need to reserve against them. It is unclear as of now whether or not this change is permanent or temporary. https://www.federalreserve.gov/newsevents/pressreleases/monetary20200315b.htm
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#2233407 - 03/20/20 05:22 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Diamond Poster
Joined: Dec 2015
Posts: 1,113
Midwest
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Thank you both for your responses.
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#2233526 - 03/23/20 07:57 PM
Re: Reg D Excessive Transfers
Bankwoman1
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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The Fed's rule says nothing about fees you charge your customers. It is only concerned with your ability to keep them from exceeding the 6/month transfer limitation. So you certainly can waive the fees without triggering any examiner critique.
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#2233715 - 03/26/20 05:42 PM
Re: Reg D Excessive Transfers
John Burnett
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Gold Star
Joined: Nov 2001
Posts: 447
New England
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I plan to waive the fee; however I am concerned about customers hitting the 3 months in a rolling 12 month period very quickly it this stretches out. Quite honestly the 1st and 2nd letters do not get their attention, it is the fee that gets their attention.
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#2233771 - 03/27/20 01:56 PM
Re: Reg D Excessive Transfers
mmason
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New Poster
Joined: Feb 2013
Posts: 22
WI
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I am also concerned about customers hitting the 3 months in a rolling 12 month period very quickly. Our state is currently under a Safer at Home order and I anticipate more will be using electronic means to pay bills and transfer funds. I am feeling a little guilty sending out the letters reminding them to stay within the limits.
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#2233772 - 03/27/20 02:09 PM
Re: Reg D Excessive Transfers
Bankwoman1
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10K Club
Joined: Jul 2001
Posts: 84,564
Galveston, TX
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Personally, under the circumstances, I think this might be about number 152 on my list of a 100 things to worry about right this minute.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2233882 - 03/30/20 02:57 PM
Re: Reg D Excessive Transfers
Bankwoman1
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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I am in Randy's camp on this question. With reserve requirements knocked to $0 it's not likely that strict adherence to the §204.2(d)(2) definition of "savings account" is going to be a top priority with regulators.
That said, you can't totally ignore the matter and give customers free rein on transfer limits.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2233915 - 03/30/20 05:44 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Diamond Poster
Joined: Dec 2015
Posts: 1,113
Midwest
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Thanks again for all the responses on this post. I was out last week as our bank has went to alternating groups of employees working by week. We don't charge a fee when the customer goes over their limit, we actually shut down their transfer abilities when we send out the 2nd notification letter. I was also feeling kind of guilty doing this when we are being told by state and federal government to stay home. Looking at my report today after being out for a week, we have a lot of customers who went over their limits during the last week. I have emailed my supervisor to see if we could make a bank decision to not shut down transfer abilities during this time, at least until the lobbies open back up, and simply have our CSR's call customers and discuss options to keep them from consistently going over their limit. I would of course keep detailed notes as to why we did this, when we started and when we stopped.
Thanks again!
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#2235599 - 04/24/20 02:51 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Power Poster
Joined: Aug 2002
Posts: 3,094
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Today, Reg D was amended. Restriction on transfers has been removed.
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#2235603 - 04/24/20 03:05 PM
Re: Reg D Excessive Transfers
ahou
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Junior Member
Joined: Jun 2007
Posts: 36
Ohio
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#2235605 - 04/24/20 03:07 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Platinum Poster
Joined: Jun 2001
Posts: 848
Texas
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I am confused. Is this effective today or out for comment?
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“The wise know their limitations; the foolish do not.†Benjamin Hoff, The Tao of Pooh
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#2235606 - 04/24/20 03:11 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Power Poster
Joined: Oct 2000
Posts: 5,992
Soaring over Georgia
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The suspension of the limits is effective as of 4/23/2020. This is an interim final rule, so the effective date for the rule is date of publication in Federal Register, but also open for any comment from the public for period specified - 60 days after publication in FR.
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#2235607 - 04/24/20 03:12 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Power Poster
Joined: Aug 2002
Posts: 3,094
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Federal Reserve Board announces interim final rule to delete the six-per-month limit on convenient transfers from the "savings deposit" definition in Regulation D For release at 10:00 a.m. EDT The Federal Reserve Board on Friday announced an interim final rule to amend Regulation D (Reserve Requirements of Depository Institutions) to delete the six-per-month limit on convenient transfers from the "savings deposit" definition. The interim final rule allows depository institutions immediately to suspend enforcement of the six transfer limit and to allow their customers to make an unlimited number of convenient transfers and withdrawals from their savings deposits at a time when financial events associated with the coronavirus pandemic have made such access more urgent. The regulatory limit in Regulation D was the basis for distinguishing between reservable "transaction accounts" and non-reservable "savings deposits." The Board's recent action reducing all reserve requirement ratios to zero has rendered this regulatory distinction unnecessary. Concurrently, the Federal Reserve is making temporary revisions to the FR 2900 series, FR Y-9, and FR 2886b reports to reflect the amendments to Regulation D.
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#2235610 - 04/24/20 03:21 PM
Re: Reg D Excessive Transfers
RVFlyboy
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Platinum Poster
Joined: Jun 2001
Posts: 848
Texas
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Thank you RVFlyboy!
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“The wise know their limitations; the foolish do not.†Benjamin Hoff, The Tao of Pooh
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#2235611 - 04/24/20 03:28 PM
Re: Reg D Excessive Transfers
Adam Witmer
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Platinum Poster
Joined: Jun 2001
Posts: 848
Texas
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The FRB basically clarified that you still have to monitor for excessive withdrawls but should attempt to work with customers, by converting/reporting applicable accounts as transaction accounts. I see, on Page 6, that the interim final rule includes the deletion of the provisions in the savings deposit definition that require the bank to monitor savings deposits ex post for violations of the limit. Am I misunderstanding that provision?
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VMACK CRCM
“The wise know their limitations; the foolish do not.†Benjamin Hoff, The Tao of Pooh
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#2235612 - 04/24/20 03:29 PM
Re: Reg D Excessive Transfers
Bankwoman1
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10K Club
Joined: Jul 2001
Posts: 84,564
Galveston, TX
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That was posted by Adam to this thread before the release today of the new rules.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2235613 - 04/24/20 03:32 PM
Re: Reg D Excessive Transfers
rlcarey
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Platinum Poster
Joined: Jun 2001
Posts: 848
Texas
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Thank you! I stay in a state of confusion lately.
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VMACK CRCM
“The wise know their limitations; the foolish do not.†Benjamin Hoff, The Tao of Pooh
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#2235632 - 04/24/20 05:17 PM
Re: Reg D Excessive Transfers
Bankwoman1
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Diamond Poster
Joined: Apr 2013
Posts: 2,284
The West
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Decisions to be made.
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