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#244712 - 09/15/04 04:39 PM Reg D transaction restrictions
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
Can a bank place a more restrictive transaction limitation on customers than the regulation allows?

For example, the reg allows 6 transfers/3 by check (summarizing here) per statement cycle/month/4 weeks. Can a bank implement a policy of only allowing one transaction within this time frame? And to add to this, could the bank assess a monetary penalty for exceeding the one transaction limitation?

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#244713 - 09/15/04 05:01 PM Re: Reg D transaction restrictions
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes, on all counts, assuming there are no state prohibitions on such a fee.

As a different example, a bank can offer an MMDA without allowing check payments at all. That makes it a lot like a savings account, but they're both covered in the same regulatory description in Regulation D, anyhow.

Just be sure that you don't rely on your more restrictive limits and fee to protect your bank from Reg. D problems. If you mistakenly let a customer go over the Reg. D limits, and don't take appropriate action, you could be criticized.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#244714 - 09/16/04 01:13 PM Re: Reg D transaction restrictions
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
Thank you John!

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