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#296220 - 12/30/04 05:00 PM Reg D and Internet Bill Payment
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
We're promoting internet bill payment services and savings accounts together. My concern is that if customers begin paying third parties out of their savings, wouldn't they violate Reg D after 3 third party payments? The Reg states "made by check, draft, debit card, or similar order and payable to third parties", but doesn't specifically cover these...

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General Discussion
#296221 - 12/30/04 05:42 PM Re: Reg D and Internet Bill Payment
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
Bill payment transactions from a savings account/MMDA are subject to the transaction limits in Regulation D. They will fall under the 3 or 6 per month limit depending on how the transactions are made (ACH/check) and whether the bank uses a third party agent. Click HERE for an article that explains in more detail.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#296222 - 12/30/04 06:28 PM Re: Reg D and Internet Bill Payment
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
Thank you, thank you, thank you! This is wonderful. From our standpoint, it looks like if it's not ACH, it falls within the three transaction limit...

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