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#2273800 - 08/04/22 03:58 PM Regulation D Excess Transactions
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,065
In the mountains
The interim final rule (April 2020) allows, but does not require, financial institutions to suspend enforcement of the six-transfer limit and to allow their customers to make an unlimited number of convenient transfers and withdrawals from their savings deposits.

The FI I work for kept the transfer limits. They are now considering changing that. Since this was "suspended" does that mean that this can be changed back to a requirement for limited transactions? If so, should management be wary that this could change back sooner rather than later and would cause a lot of extra work to stop and then restart the limiting of transactions if it becomes a requirement again?
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#2273803 - 08/04/22 04:20 PM Re: Regulation D Excess Transactions Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,336
Galveston, TX
It is never coming back.
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#2273805 - 08/04/22 05:54 PM Re: Regulation D Excess Transactions Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,336
Galveston, TX
Reserve requirements, the prohibition of interest on demand deposits, transaction limitations on savings accounts were all rudimentary tools that the Fed Res developed in the early days in an attempt to control and manipulate monetary flows, liquidity, etc. The Fed has developed much more powerful tools since those were originally designed and they no longer serve any real purpose in the grand design of economic controls. As such, while I know never to say never, it just is not going to happen.
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#2273813 - 08/04/22 07:05 PM Re: Regulation D Excess Transactions Likes to Comply
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,590
On the Net
Could it come back, sure. But I don't believe it is on anyone's wish list as it simply isn't necessary. Randy explained that. It is an opportunity to earn fee income but could be a marketing disadvantage when in place. Still having it also makes people think it could still apply. If your bank doesn't enforce this, I wouldn't put it out there.
Last edited by Andy_Z; 08/04/22 07:11 PM.
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