In April, 2020, the Fed issued an interim final rule to amend Regulation D to delete the limits on transfers and withdrawals that may be made each month from a savings account. At that time, we relaxed the 6-withdrawal limit for our customers and waived the associated fees. Has anyone heard anything about this rule? Was it ever made permanent? Does anyone have an update on this… did you update your disclosures to reflect this change at that time and has anyone started charging the fee again to their customers?

You can go here: https://www.bankersonline.com/regulations/12-204-000

And then here: Click HERE for a table of recent Federal Register and other documents affecting this regulation.

For the latest on all the regulations in the BOL collection.

But no - it has not been finalized.

Whoa!

Interim final doesn't mean it is temporary. It just means that it was issued as a final rule without a proposal or advance comment period (the comment period followed the final rule in this case). At some point, the Fed will need to make it final, and in doing so it might make a tweak or two. Some interim final rules stay on the books for years before the issuing agency changes their status to just plain "final."

So, it's correct to say this one hasn't been finalized. But don't think that means it's temporary or not permanent (at least until something else comes along).

Your bank can decide to make its change permanent, or it can go back to imposing limits -- either the complex limits that used to be in the regulation or limits of the bank's choosing. If you come up with your own limits, you will need to advise consumers of them in advance and make sure your account disclosures are brought current.

If you go back to the old limits that were in the regulation, you should advise your customers when that will start, not because Reg DD says so, but because it will be the right thing to do.

And because if you don't do what you have disclosed, you could possibly be looking at a UDAAP issue.