Someone brought this to my attention today and I don't recall having looked at this before.

Should we count an ODP loan payment debit toward our Reg D limits? Initially, I thought all loan payment debits were not counted, but they pointed out the following verbiage in the FDIC rules and I think I was wrong. What do you think?

329.101 Transfers from a deposit described in § 329.1(b)(3) that are made to the bank are not deemed to be included within the six transfers permitted for a nondemand deposit by that paragraph (3) when the transfers are made for the purpose of repaying loans and associated expenses at the bank (as originator or servicer). This exemption does not apply to transfers to the bank that are made for the purpose of repaying loans that are made by the bank to the depositor's demand account for the purpose of covering overdrafts.