We have a customer that has exceeded limits 3 times within twelve month period. We are closing the savings account and moving to another account. They are wanting to know how long before they can open a savings account again. I said 1 year. Does that sound reasonable? What does your bank do?

There is no guidance. You really want to start monitoring this customer again?? Maybe if they are a large balance customer.

Our policy was to agree to start again, but only once, under the theory that actually closing the account showed the customer we weren't slinging BS. But the first time that customer strayed over the line (not the third, the first) on the new account, we gave him the boot and blacklisted him for any more savings/MM accounts.

John, are you saying you would immediately let the customer open a new savings account?

I don't think we had a "cooling off" period in our "program." It was over 15 years ago that I last had to care about it. I don't think it's a really big detail, frankly, since when your regulator looks at this rule the major focus should be on your overall results -- is an infraction an infrequent thing?