Are wire transfers from a savings/MMDA account (initiated by phone or preauthorization)to a third party, counted as one of the three or one of the six?

It's not a check or similar device, so I would say six.

Wire transfers regardless of beneficiary, if requested by phone is subject to 3.
Wires regardless of beneficiary, if requested in person, by messenger, or by mail have no limits.

Per FRB 12 CFR-204...A handout given to me by our Internal Auditor provided by the ABA.

I think it's silly but I didn't make the rules. Now, if I did....

Is this an FRB advisory letter? Where can I find this "handout"? Thanks.

Swede - Tell me again how a telephone order to the bank to do a wire transfer is a transfer made by check, draft, debit card, or similar order made by the depositor and payable to third parties??? I don't buy it.

From a FRB Staff letter in September 1996:

The overall limitation on restricted transfers and withdrawals is six per month. In addition, checks, drafts, debit card transactions and "similar orders to third parties" are limited to three per month. Board staff noted in 1992 that "[p]oint-of-sale transactions with either ATM or credit card company debit cards and withdrawals payable to third parties initiated by checks or drafts" are subject to the three-transaction limit while "telephone, fax, and computer transactions to transfer funds to another account at the same institution" and "withdrawals initiated by telephone where the proceeds are payable to third parties" are subject to the six-transaction limit . Staff Opinion of July 13, 1992, Federal Reserve Research Service 2-342.22.

FRB provided the following guidance to us in 2005: walk in wire does not count toward limits (in person transaction), telephone order counts toward pre-authorized limit of 6 (initiated by telephone).

We have been working with JHA to create new wire transfer codes to insure that we can accurately track the limits on our MMA and NOW products. The update will be included in JHA's 2006 release.

Randy-Because our compliance/auditor said so. It's just makes it easier to listen to her. (Learned that one the hard way. haha)

The handout was dated in 1994 so I was thinking that maybe it changed. But with Brenda's info, apparentely, it hasn't.

Brenda, did they give you a website reference? I have a chart that lists what is what but if they have an updated one, it would help.

I'm in Randy's camp. A telephone order to wire funds is not a "similar order to a third party." Not a 3/month item.

Here's the logic that I am thinking of (granted, I'm often illogical and there's definately no logic to banking)

Why wouldn't a wire be towards the three? The end user is a third party entity and it's not a reoccuring transaction (like an ACH). It's just a different mechanism to transfer the money one time.

Because the Fed settled the issue in 1992 with the above staff opinion.

Forget logic and go with the flow. A wire is not similar to a check, draft or debt card - you don't normally carry one around with you in your back pocket.

Banks originate and receive wire transfers. Customers do not.

If a customer came in to withdraw money and happens to use it to pay for a wire, that's an in person withdrawal and it does not count. If a customer phones the bank to withdraw money and happens to use it to pay for a wire, that's a telephone withdrawal and it counts as one of the six allowable per month.