Skip to content
BOL Conferences
Thread Options
#2261467 - 10/22/21 06:22 PM Reg D clarification
c@c Offline
100 Club
Joined: Mar 2008
Posts: 120
Georgia
Will someone clarify for me where the Reg D transaction limitation revision landed? There were amendments to Reg D earlier this year, but as best I can tell it did not address making the elimination of the 6 transactions per month/quarter a permanent thing. Did I overlook it or are we still making decisions based on a FAQ that says the Fed expects it to be permanent?

Return to Top
Deposits and Payments
#2261469 - 10/22/21 06:26 PM Re: Reg D clarification c@c
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2261476 - 10/22/21 06:45 PM Re: Reg D clarification rlcarey
c@c Offline
100 Club
Joined: Mar 2008
Posts: 120
Georgia
Thanks Randy. My question should have been whether or not the interim final rules was ever made permanent, but I'll take your response as it has not been and go from there. I appreciate the feedback.

Return to Top
#2261479 - 10/22/21 06:59 PM Re: Reg D clarification c@c
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
You are likely never to see a final rule:

https://www.federalreserve.gov/supervisionreg/savings-deposits-frequently-asked-questions.htm

Are the recent amendments to Regulation D temporary or permanent?

On April 24, 2020, the Board of Governors issued an interim final rule amending its Regulation D to delete the six-per-month limit on convenient transfers from "savings deposits." The underlying reason enabling the changes in Regulation D is the FOMC’s choice of monetary policy framework of an ample reserve regime. In such a regime, reserve requirements are not needed. As a result, the distinction made by the transfer limit between reservable and non-reservable accounts is also not necessary. The Committee’s choice of a monetary policy framework is not a short-term choice. The Board does not have plans to re-impose transfer limits but may make adjustments to the definition of savings accounts in response to comments received on the Board’s interim final rule and, in the future, if conditions warrant.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2261567 - 10/25/21 09:28 PM Re: Reg D clarification c@c
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The rule was issued as an interim final rule because the Fed felt it was an opportunity to not only get rid of the limits but also to provide savers who may have been affected by the pandemic added flexibility for account access. It would have taken months to go the standard route of proposal, comment period, review of comments, final rule.

We may see a final rule, and I would bet there won't be any definitional changes in it.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2261571 - 10/25/21 10:06 PM Re: Reg D clarification c@c
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 283
Doesn't this final rule as it relates to the reserve requirements effectively remove the six-per-month limits?

govinfo.gov/content/pkg/FR-2021-02-10/pdf/2020-28756.pdf
_________________________
Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

Return to Top
#2261576 - 10/26/21 11:34 AM Re: Reg D clarification c@c
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
Inspector - That release lowered the reserve requirements to zero and did not address the transaction limits.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  John Burnett