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.

Specifically:
*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.

I'm not quite sure where they got that based on the FAQs included in the April 2020 ruling:

Q.2. May depository institutions continue to report accounts as “savings deposits” on their FR 2900 deposit reports even after they suspend enforcement of the six transfer limit on those accounts?
A.2. Yes. Depository institutions may continue to report these accounts as “savings deposits” on their FR 2900 reports after they suspend enforcement of the six transfer limit on those accounts.

Q.3. If a depository institution suspends enforcement of the six transfer limit on a “savings deposit,” may the depository institution report the account as a “transaction account” rather than as a “savings deposit”?
A.3. Yes. If a depository institution suspends enforcement of the six transfer limit on a “savings deposit,” the depository institution may report that account as a “transaction account” on its FR 2900 reports. A depository institution may instead, if it chooses, continue to report the account as a “savings deposit.”

For reference, the interim final rule can be found here: https://www.federalregister.gov/doc...-requirements-of-depository-institutions

Thank you SO much Adam! I thought I had completely lost my mind and was questioning my comprehension! I knew I had read those FAQs somewhere but couldn't locate them so I really appreciate the link. I'm just so shocked as this is one of the two most popular consulting and auditing firms in our area that published that.

Again - thank you!

Well, none of us get it all right all of the time, especially since things have been a moving target lately. Maybe they know something we don't, so it would probably be worth reaching out to them. That said, the updated May FAQs at the following link still reference the same info on the FR 2900 reports: https://www.federalreserve.gov/supervisionreg/savings-deposits-frequently-asked-questions.htm.

"I knew I had read those FAQs somewhere but couldn't locate them so I really appreciate the link"

Your Compliance Department should have a tracking log of all regulatory changes. If one is not available, they should implement one. You should be able to find some templates online.

You can report those accounts as savings deposits or transaction accounts on the FR 2900. But don't lose track of which is which, because you will need to make a distinction to complete the 6/30/20 Call Report, and there you won't be able to put the balances in whichever block you feel like.

The ABA is asking the Fed to sort out the way in which the FFIEC agencies want deposits separated, and consider doing away with the FR 2900. Don't hold your breath waiting.