The definition of a NOW account remains unchanged.
Options include:
a) Risk-based audit schedule. (When was the last time you were examined for Reg D? What are the risks to the bank if you get it wrong))
b) Convert your NOW accounts to interest bearing checking accounts (remove the reservation of 7-days notice prior to withdrawal report the accounts accordingly on your call report) since Reg Q has been repealed and eliminate the requirement all together.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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