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#244683 - 09/15/04 03:17 PM REG D- Transfers made by email
Anonymous
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We have a customer that wants to set up a Money Market account and wants to make transfers via email (not through the the typical internet transfer process, but an actual email to a bank employee). Any restrictions on the # of transfers they can make a month or statement cycle? We are wanting to treat it like a telephone transfer, which would not have restrictions. What do you think?

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#244684 - 09/15/04 03:23 PM Re: REG D- Transfers made by email
Andy_Z Offline
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If they email or call and you transfer the funds to another account (DDA) of theirs, this would be a sweep type arrangement and would be limited. If you send them a check it wouldn't count.
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#244685 - 09/15/04 04:20 PM Re: REG D- Transfers made by email
John Burnett Offline
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John Burnett
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Cape Cod
Quote:

We are wanting to treat it like a telephone transfer, which would not have restrictions. What do you think?




I think you should re-read Regulation D, section 204.2(d)(2). Transfers made by telephone are most certainly covered by the restrictions, unless the instruction is to send the withdrawn funds by check payable to the customer.

Email is, I believe included within the phrase "telephonic (including data transmission) agreement, order or instruction" found in that section of the regulation. Unless the instruction from the customer were to "send me a check," you should count each such transfer in the six per month limit.
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#244686 - 09/15/04 05:04 PM Re: REG D- Transfers made by email
Anonymous
Unregistered

Thanks for catching that. My error.

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#244687 - 09/15/04 06:30 PM Re: REG D- Transfers made by email
Bank Angler Offline
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Just a short drive from Lake E...
Another thought. Most e-mails outside of internet banking are not encrypted or secure, so e-mails with account numbers and transfers should be avoided.
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#244688 - 09/15/04 07:07 PM Re: REG D- Transfers made by email
mrenderman Offline
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mrenderman
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Wisconsin
That was my thoughts exactly. I would make sure that if the e-mails are not secured, that you notify the customer that his information may be compromised by sending it through e-mail. I wouldn't feel comfortable with my customers sending any personal information through the e-mail.

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#244689 - 09/16/04 01:54 PM Re: REG D- Transfers made by email
Andy_Z Offline
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Just be sure to edit out that confidential information if you click "Reply" and quote the message they sent you which contained it in the first place.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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