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#2182741 - 06/22/18 02:30 PM Reg D- Cashier Check Fee
WABComply Offline
100 Club
Joined: Jul 2017
Posts: 229
I am currently doing a review on excessive transfers from a savings or mma account and I need an opinion. In conducting a review I came across an account in which the customer purchased multiple cashier's checks. The Bank processes this which what seems to be 2 transactions. First the fee for the cashier check and then for the amount of the check. The way I read the regulation is that each transaction should count towards the 6. The fee is not a deposit directly to the customer and not a payment on a loan to the Bank so I want to include it. I cannot find anything that says otherwise.

If you can please offer your opinion and maybe some backup I would very much appreciate it. This is my first time completing such a review and I just need to make sure I understand the regulation correctly. Thanks in advance.

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#2182749 - 06/22/18 02:55 PM Re: Reg D- Cashier Check Fee WABComply
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,724
Illinois
A bank fee is not an external payment to a third party and would not be counted.
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#2182754 - 06/22/18 03:11 PM Re: Reg D- Cashier Check Fee WABComply
WABComply Offline
100 Club
Joined: Jul 2017
Posts: 229
I think I got it now thanks. I think that either way this type of transaction would not count, the purchase of the check, and the check even though they are made to a third person as these are "inconvenient" transfers as the customer needed to come in directly to the branch to complete the transaction.

I also do see your point, that the Bank is not a third party. I confused that with the auto-payment to same institution requirement not to include.

Thanks again.

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#2182756 - 06/22/18 03:12 PM Re: Reg D- Cashier Check Fee WABComply
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,724
Illinois
You got it!

Since the transaction was processed at the teller window, the cashier's check purchase doesn't count any more than if I withdrew the money in cash at the teller window.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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