If a customer comes into the bank and we debit his account for a wire transfer, should this count towards the six transfers per month limit in Reg D? It looks to me like it should.

Thanks.

Debiting the customer's account for a wire transfer would not count against the customer's 6 transfers per month under Reg D if the customer initiated the transfer in person. The limitations under Reg D apply to preauthorized transfers, telephone transfers, etc.; they don't apply to transactions intitiated in person or through an ATM.

[This message has been edited by SteveMc (edited 01-24-2002).]

The reason I am questioning whether they should count is that the wire transfer would most likely be going to a third party rather than to the customer themselves. Reg D makes it sound like the payment must go directly to the customer for it not to count.

The key element in your question is that the customer came into the bank. That gets the transaction out of the six count for purposes of the regulation. However, you could still have an issue with your internal tracking. Many operating systems don't have a way to distinguish whether the wire was pre-authorized or requested by an in-person visit to the bank. What to do if this is the case becomes a management decision.