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#2235641 - 04/24/20 06:13 PM Re: Reg D Excessive Transfers Bankwoman1
NoJustNo Offline
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Joined: Oct 2013
Posts: 209
Midwest
Is this Reg. D change permanent? I keep seeing references to "suspend" but the wording makes it seem permanent.

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#2235644 - 04/24/20 06:18 PM Re: Reg D Excessive Transfers NoJustNo
Reads Regs Offline
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I wonder why the FRB put something about six months in Q&A 10 of their FAQs? https://www.federalreserve.gov/supervisionreg/savings-deposits-frequently-asked-questions.htm
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#2235645 - 04/24/20 06:20 PM Re: Reg D Excessive Transfers Bankwoman1
rlcarey Offline
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Galveston, TX
It is just giving you the option
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#2235652 - 04/24/20 07:12 PM Re: Reg D Excessive Transfers NoJustNo
Red Raiders Offline
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Red Raiders
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Compliance Land
I also have the question of "is this permanent or temporary?". My reading of it makes it seem that it is permanent as they don't say anywhere "temporarily" (that I saw anyway). Any thoughts?
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#2235656 - 04/24/20 07:26 PM Re: Reg D Excessive Transfers Bankwoman1
BrianC Offline
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BrianC
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Illinois
In order to "reinsert" that language into Regulation D, the Fed would have to provide another proposal of rulemaking, comment period, etc. This appears to be a shift in monetary policy.
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#2235657 - 04/24/20 07:26 PM Re: Reg D Excessive Transfers Bankwoman1
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
If I understood what "ample reserves regime" meant I think it would go a long way to understanding why the Fed took this action. Can anyone explain that?

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#2235675 - 04/24/20 08:28 PM Re: Reg D Excessive Transfers Bankwoman1
mnbanker09 Offline
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Is my assumption accurate that we do not need to provide an advance notice of amendments to our account agreements? We can choose not to enforce the restrictions effective immediately, and notify the customer in the next 30 days?

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#2235676 - 04/24/20 08:32 PM Re: Reg D Excessive Transfers Bankwoman1
BrianC Offline
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BrianC
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Illinois
This change is to the customers' benefit so there is no advance notice needed. Whether/how you notify customers or not is a business decision.
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#2235702 - 04/27/20 02:27 PM Re: Reg D Excessive Transfers Bankwoman1
Dodge Offline
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Can we stop monitoring, no changes to notices or anything, but basically stop reviewing and sending letters? Decide a more temperament t solution after the comment period? That just seems to simple.

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#2235704 - 04/27/20 02:29 PM Re: Reg D Excessive Transfers Bankwoman1
rlcarey Offline
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rlcarey
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Galveston, TX
Totally a business decision. The six transfers limitation no longer exists.
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#2235711 - 04/27/20 03:01 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
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Cape Cod
I'll be presenting a special ONE-HOUR webinar, "Limits on Savings Accounts -- An Update," to explain the ins and outs of the Fed's action on Monday, May 18.

Why should the kids have all the "remote learning" fun?
Last edited by John Burnett; 04/27/20 07:26 PM.
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#2235715 - 04/27/20 03:10 PM Re: Reg D Excessive Transfers John Burnett
travelgirl1 Offline
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Joined: Sep 2015
Posts: 86
If the change is permanent and effectively immediately, what would be a business reason to continue with your current process? The rule states the bank has the option to continue. Why would anyone want to keep doing the work? I want to make sure I'm not missing something that seems so straight forward - stop monitoring and sending notices to anyone exceeding the six withdrawal limit. Send a notice if you so choose notifying customers, make updates to your disclosures, website, etc. where there is mention of the limitations.

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#2235723 - 04/27/20 03:36 PM Re: Reg D Excessive Transfers Bankwoman1
Adam Witmer Offline
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Why would anyone keep doing the work? To maintain the infrastructure of a process than could again become a requirement. As Brian mentioned earlier in this thread, the reserve requirements (and the transaction monitoring) is part of the Fed's monetary policy. With the current state of affairs, this action is understandable. However, as the economy recovers, the Fed may decide to make adjustments to their monetary policy, which could be similar to what they have done before. Some may choose to keep the infrastructure of their program in place for a while in hopes of getting a feel for what the Fed may do when the economy recovers.
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#2235735 - 04/27/20 04:48 PM Re: Reg D Excessive Transfers Bankwoman1
smh Offline
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Joined: Jul 2018
Posts: 9
There is some notion within our institution that this is a temporary change to Reg D. Does anyone know of a citation for that? From what I can tell this is a permanent change. Obviously with big implications. Is there a reason to think it is not permanent?

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#2235736 - 04/27/20 04:51 PM Re: Reg D Excessive Transfers BrianC
BrianC Offline
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Illinois
Originally Posted by BrianC
In order to "reinsert" that language into Regulation D, the Fed would have to provide another proposal of rulemaking, comment period, etc. This appears to be a shift in monetary policy.


I answered the comment on "permanent vs. temporary" in post #2235656 on a previous page of this discussion.
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#2235738 - 04/27/20 04:58 PM Re: Reg D Excessive Transfers BrianC
smh Offline
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Thanks Brian, I appreciate that.

What's to stop the fed from just dropping this on us again with an interim rule like they've done here? It just seems very difficult for us to advise our customers with any authority. This feels like a sea change that has come from, almost, nowhere.

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#2235739 - 04/27/20 05:03 PM Re: Reg D Excessive Transfers Bankwoman1
rlcarey Offline
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rlcarey
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Posts: 80,357
Galveston, TX
I am not sure why anyone would go out of their way to advise customers of the change - just quit monitoring.
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#2235740 - 04/27/20 05:11 PM Re: Reg D Excessive Transfers rlcarey
smh Offline
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Joined: Jul 2018
Posts: 9
Thanks, Randy. I suppose I meant more our business partners within the organization.

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#2235742 - 04/27/20 05:28 PM Re: Reg D Excessive Transfers rlcarey
travelgirl1 Offline
Member
Joined: Sep 2015
Posts: 86
And remove any mention of the limitations in account opening disclosures and marketing materials.

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#2235743 - 04/27/20 05:32 PM Re: Reg D Excessive Transfers travelgirl1
travelgirl1 Offline
Member
Joined: Sep 2015
Posts: 86
I agree Randy, notification to the customer is not needed, although I think some of our customers would be glad to know this limitation no longer exists. Simple statement message on a future quarter-end statement cycle is easy enough.

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#2235759 - 04/27/20 07:32 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,868
Cape Cod
I'll be presenting a special ONE-HOUR webinar, "Limits on Savings Accounts -- An Update," to explain the ins and outs of the Fed's action on Monday, May 18.

Why should the kids have all the "remote learning" fun?
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#2235764 - 04/27/20 07:57 PM Re: Reg D Excessive Transfers Bankwoman1
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted by BrianC
This change is to the customers' benefit so there is no advance notice needed. Whether/how you notify customers or not is a business decision.

Take note, though, that there is a fair amount of online press on this amendment already, and it's not always thorough. So it's possible your customers could assume there are no longer any restrictions on their savings transfers, even if your bank hasn't eliminated them yet. You'll want to determine how to address matters if a customer doesn't understand that the bank had the option to drop the restrictions but didn't or that the bank will continue charging $25 for each withdrawal or transfer after 6 in a month (or whatever your fee structure is).

You could suspend what you're doing, including the imposition of fees, perhaps, until the economy comes back to life and people return to work, and then figure out what you're going to do going forward. Whatever it is that you decide, it will be simpler to understand, explain and control than the rule as it was last month.
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#2235787 - 04/28/20 12:24 AM Re: Reg D Excessive Transfers Bankwoman1
CL1112 Offline
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Joined: Mar 2018
Posts: 1
What is the impact to Reg CC and placing holds? Would savings accounts, now "transaction accounts," be in play to permissibly place a hold?

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#2235788 - 04/28/20 01:12 AM Re: Reg D Excessive Transfers Bankwoman1
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,437
Illinois
Reg CC continues to apply to only transaction accounts (unless your state law extends coverage to savings accounts.) There is no requirement to reclassify your savings accounts as transaction accounts. You just don't have to monitor for excessive transactions.
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#2235802 - 04/28/20 03:17 PM Re: Reg D Excessive Transfers BrianC
RR Sarah Offline
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RR Sarah
Joined: Mar 2004
Posts: 2,494
Up North
So, on the Call Report, schedule RC-E...report the savings accounts as transaction accounts if we opt to eliminate the limits?
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