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#968347 - 06/03/08 05:50 PM Reg D: 3 or 6 for ACH check
Bacon Boy Offline
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Bacon Boy
Joined: Sep 2006
Posts: 13,244
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In reviewing the latest batch of our suspected Reg D violations, I came across a client who has ACH items that include a check number. Our system recognizes these as checks (part of the 3 allowable in a statement cycle) but they're also tagged as ACH, which would lead me to shuffle them in to the 6 allowable transactions. For documentary purposes, and for notifying the client, how would you classify these debits?

Thanks in advance for your help!
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#968355 - 06/03/08 05:55 PM Re: Reg D: 3 or 6 for ACH check Bacon Boy
TXBSA Offline
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Posts: 170
TX
I would classify them as checks. They probably started out as checks and then were converted into ACH's. The customer would probably recognize them as checks that they had written.

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#970418 - 06/05/08 10:27 PM Re: Reg D: 3 or 6 for ACH check TXBSA
John Burnett Online
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
If the Fed staff is looking at our Threads, maybe they will get their proposed Reg. D changes implemented???? That would make the question moot.
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