I'm putting together a summary and recommendation for the Reg D change for our upper management. I thought I had a solid grasp on it and was a bout to hit send when I came across a summary from a local consulting group with points that I had not seen mentioned anywhere else.
*Because of the change to reserve requirements, depository institutions may allow customers to make more than six convenient transfers per month from their savings deposits (this includes both savings accounts and MMDA accounts). The caveat to this change is if your customers are allowed to exceed the transaction limitation, these account balances must be reclassified to transaction accounts when submitting the FR 2900 report.
*If your institution chooses not to reclassify your savings deposits for FR 2900 reporting purposes, you are required to continue to enforce the transfer limitations required by Regulation D.
Did everyone else get this as a take-away after reading the information distributed? Do you agree? The plan was to maintain them as "savings accounts" and charge a fee for convenient transfers totaling more than six but according to them, we need to report them as transaction accounts?
I need to send this out yet today and now I'm questioning myself.