While many banks dealing with an excessive-transfer MMDA account either close the account or convert it to a NOW or DDA, what the Feds are really getting at is getting the account to conform. So, if you can "reform" your customer by taking away check/draft capability, and successfully limit his/her thirst for transactions like ACH/telephone/auto tran/home banking and the like to the allowable numbers, you've complied with the reg. What you've in essence done is made the account a savings account.
The advice above concerning new disclosures is excellent. It's a new account, even if you use the same account number and nothing changes except you broke the customer's checkwriting hand!
Now that's an interesting idea to include in a Reg D warning notice! You stop writing so many checks, or we'll bust your fingers!
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8