At compliance meeting today it was brought up the former BSA Officer had stated you could not do a 'telepost' for transfers if the ownership was not matched on both accounts. For instance, if John calls in and wants to transfer funds via phone request to Mary, but John is not on Mary's account. Instead of doing a 'telepost' thru the teller system, you must create tickets. However, this could potentially affect the number of transactions per Reg D.

Does anyone know of an issue as far as compliance in just doing Telepost if John wants to transfer funds to Mary and John is not on her account?

Since transaction limitations are gone from Regulation D, that is now a moot point.

Most banks will not allow customers to initiate internal electronic transfers between accounts that are not titled the same without some sort of manual intervention due to the potential for fraud.

rlcarey- true. Do we have any indication the limits will be coming back?

No

See also the responses to your post in our BSA/AML forum at https://www.bankersonline.com/forum/ubbthreads.php/topics/2268295

This thread is being locked because of the duplicate in the BSA/AML forum.