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#948975 - 04/24/08 06:10 PM Reg D - excessive withdrawal
newbank Offline
Member
Joined: Dec 2007
Posts: 78
A quick question for Reg D issue: if customer comes into the bank and transfers from his personal money market account to his business money market (it is a Corp. and he is the secretary on the account), does this subject to Reg D?

Thanks.

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Operations Compliance
#949003 - 04/24/08 06:40 PM Re: Reg D - excessive withdrawal newbank
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
If the customer did the transaction face to face it is not subject to the Regulation D Requirements.
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#953912 - 05/02/08 08:02 PM Re: Reg D - excessive withdrawal Skittles
longrivers Offline
New Poster
Joined: Apr 2008
Posts: 6
texas
Another question on Reg D excessive withdrawals.
Would a debit card on a money market account used at a merchant's POS be a COVERED tranfer? and only 3 of these per month?

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#953913 - 05/02/08 08:03 PM Re: Reg D - excessive withdrawal Skittles
longrivers Offline
New Poster
Joined: Apr 2008
Posts: 6
texas
Another question on Reg D excessive withdrawals.
Would a debit card on a money market account used at a merchant's POS be a COVERED tranfer? and only 3 of these per month?

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#954044 - 05/02/08 10:35 PM Re: Reg D - excessive withdrawal longrivers
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Yes. Only 3/month, since it is a POS.
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#962387 - 05/20/08 10:32 PM Re: Reg D - excessive withdrawal David Dickinson
newbank Offline
Member
Joined: Dec 2007
Posts: 78
Thanks, David. What if customer comes to the bank and writes a check from his money market to another account holder's business account of the bank?
Thanks.

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#962420 - 05/20/08 11:28 PM Re: Reg D - excessive withdrawal newbank
GuitarDude Offline
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GuitarDude
Joined: Nov 2004
Posts: 5,924
So Cal
IMHO that would count in the "3 bucket."
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#963388 - 05/22/08 01:26 PM Re: Reg D - excessive withdrawal GuitarDude
Oviedo Boy Offline
Platinum Poster
Joined: May 2006
Posts: 629
Tennessee
Question...we have a customer that is a repeat offender in excessive transactions on his Money Market...we've exhausted the 3 letter cycle we normally go through, and have contacted the account officer. The officer does not want to move the customer to another account...what are the regulatory risks to the bank if this is not properly addressed? CMP's? Reserve adjustments?
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#964196 - 05/23/08 12:55 AM Re: Reg D - excessive withdrawal Oviedo Boy
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,503
On the Net
Complete terror.

Seriously, you'd run the risk in the extreme of having your portfolio (not just that account) classified as a DDA product. So lets go back X months or years to the beginning of the problem and recalculate the reserves you should have had. Oh, looks like you were short based on all these new DDA accounts. That could be a penalty. It is certainly a nightmare.

I heard once of a bank where the examiners were considering making the board pay the bank back the interest that was paid on these now DDAs. (I told my board that and had complete cooperation in this matter.)

Basically, it isn't worth it. At the very best you'll tell your examiner that you don't care about that law and you'll accept whatever penalty they choose.

The net, net, net is that it isn't really up to the bank or its officer to decide which laws and policies you decide to follow today.
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My opinions are not necessarily my employers.
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#964828 - 05/23/08 07:43 PM Re: Reg D - excessive withdrawal Andy_Z
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
Don't you love officers that don't want to follow the law?

GuitarDude always has the best avitars. My Dallas Stars avatar feels so jealous.

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