repeal of part 329

Posted By: beagleboy

repeal of part 329 - 09/02/14 05:52 PM

FDIC repealed part 329 in 2011. Did the repeal also include the transaction limitations on MMA and svgs accounts?
Posted By: rlcarey

Re: repeal of part 329 - 09/02/14 05:53 PM

Did the repeal also include the transaction limitations on MMA and svgs accounts?

Those limitations are found in Regulation D (12 CFR 204).
Posted By: beagleboy

Re: repeal of part 329 - 09/02/14 06:09 PM

Yes, I know where the limitations are found, but did the repeal of part 329 remove the limitations on these accounts?
Posted By: beagleboy

Re: repeal of part 329 - 09/02/14 06:10 PM

Are banks that are regulated by FDIC exempt from the limitation requirements of reg D?
Posted By: manimal

Re: repeal of part 329 - 09/02/14 06:11 PM

No, transaction limitations are still there in Reg. D. And yes, FDIC banks are subject to them.
Posted By: Kathleen O. Blanchard

Re: repeal of part 329 - 09/02/14 06:11 PM

No the transaction limitations (now at 1004, not 204) were not repealed, they have been adjusted. And FDIC regulated banks are not exempt.
Posted By: rlcarey

Re: repeal of part 329 - 09/02/14 06:39 PM

ahh - KB - Regulation D is still 12 CFR 204 - it was not transferred to the CFPB.

12 CFR 1004 would be the Alternative Mortgage Transaction Parity regulations.
Posted By: Kathleen O. Blanchard

Re: repeal of part 329 - 09/02/14 06:46 PM

And you are right! Stayed up too late last night working!
Posted By: John Burnett

Re: repeal of part 329 - 09/02/14 06:59 PM

OK. To sum up. The repeal of FRB Regulation Q (Part 217) and FDIC Part 329 were not related in any way to the FRB's Regulation D (Part 204). Regulation D remains in effect, including its definitions (and the restriction in those definitions) of savings accounts, which includes money market deposit accounts.

And you didn't ask, but there also no change to the definition of, or the restrictions on ownership of, NOW accounts.
Posted By: Ann

Re: repeal of part 329 - 01/05/15 09:24 PM

Just curious, I know it is not repealed, but I can not find examination procedures for this in the FDIC Compliance Examination Manual. Am I missing something in the manual?I thought it was there at one time.
Posted By: rlcarey

Re: repeal of part 329 - 01/05/15 10:09 PM

Examination procedures for what?
Posted By: John Burnett

Re: repeal of part 329 - 01/05/15 10:20 PM

Wild guess is she is asking about Reg D transfer limits on savings accounts.
Posted By: rlcarey

Re: repeal of part 329 - 01/06/15 12:59 AM

Well, it was lumped into in the Interest on Deposits section of the exam manual which has been deleted.
Posted By: John Burnett

Re: repeal of part 329 - 01/06/15 04:54 PM

Classic example of tossing out the baby with the bathwater.