We are looking to institute sweep accounts where as the DDA account may be at zero or another set amount. Deposits can be made to a MMDA or DDA. Funds are then swept from MMDA to cover daily expenses or swept to MMDA when the DDA account gets to high the dollars are swept into the MMDA account. My question is does Reg D apply. I am getting conflicting advise and need to know which side of fence to fall off onto the ground. HELP, PLEASE!

Reg D would apply. Those would be considered pre-authorized transactions. We also tie our MMDA's to regular checking accounts, but the transfers are included in the limit. I have had to write letters just this week for this very situationl.

Thank you. That is what I thought. I am pretty sure our software can track this, so it may not be too bad. I really appreciate your response. Have a great weekend. Don't forget to Spring Ahead this weekend.