We are considering a voice response system for our bank. Can anyone think of any compliance issues that we need to consider other than Reg D's transfer limitations and the applicability of Reg E (if there is a written agreement)?

GLBA Section 501(b) / Info. Security.

If you will post rates on your VRU, you need to take a look at the advertising rules in Regulations DD and Z.

Our VRS feature for merchant verification of customers' checks did not have sufficient controls, so we turned it off. Anyone could call any number of times on a given account, so eventually they could zero in on the exact balance in the account - or any account, for that matter.

Am I correct in thinking that transfers initiated on the VRU count toward the 6 monthly transfers from savings/MMDAs allowed by Reg D?

That's a good point about systems that allow merchant verifications. I'll be sure to pass that on to management if they are considering such a function!

Yes, VRU transfers count towards the 6 monthly transfers allowed by Reg D.

Whose ox are you calling a moron??

And if your VRU will accept loan applications, consider GMI as well.