I am signing in anonymously because I feel I am asking a dumb question.

I've read the definitions sections of Reg. D several times and I still can't seem to come up with an answer to this. Are IRA savings accounts subject to Reg. D withdrawal limitations? At first, I was thinking that they would be. Then, I was waivering because technically, money is only supposed to go into these accounts, not out. So, I am not sure if I should have my system set up to have a Reg D flag on these accounts or not.

Would you allow a customer to have ACH or a debit card on their IRA account? I've never heard of that, and that is where I would think you have the most exposure. If a customer is legally withdrawing due to age, disability or death, I would think they probably would not violate the limitations. (They take their "regular" distribution and maybe another one here or there, but not much more.)

BTW, there is no such thing as a dumb question on BOL!

Reg D applies to anything that meets the definition of a savings account, regardless of who the owner is or in what capacity ownership is held.

You failed to meet the test for a dumb question - people understood what you were talking about!