Reg D clarification

Posted By: c@c

Reg D clarification - 10/22/21 06:22 PM

Will someone clarify for me where the Reg D transaction limitation revision landed? There were amendments to Reg D earlier this year, but as best I can tell it did not address making the elimination of the 6 transactions per month/quarter a permanent thing. Did I overlook it or are we still making decisions based on a FAQ that says the Fed expects it to be permanent?
Posted By: rlcarey

Re: Reg D clarification - 10/22/21 06:26 PM

https://www.federalregister.gov/doc...-requirements-of-depository-institutions
Posted By: c@c

Re: Reg D clarification - 10/22/21 06:45 PM

Thanks Randy. My question should have been whether or not the interim final rules was ever made permanent, but I'll take your response as it has not been and go from there. I appreciate the feedback.
Posted By: rlcarey

Re: Reg D clarification - 10/22/21 06:59 PM

You are likely never to see a final rule:

https://www.federalreserve.gov/supervisionreg/savings-deposits-frequently-asked-questions.htm

Are the recent amendments to Regulation D temporary or permanent?

On April 24, 2020, the Board of Governors issued an interim final rule amending its Regulation D to delete the six-per-month limit on convenient transfers from "savings deposits." The underlying reason enabling the changes in Regulation D is the FOMC’s choice of monetary policy framework of an ample reserve regime. In such a regime, reserve requirements are not needed. As a result, the distinction made by the transfer limit between reservable and non-reservable accounts is also not necessary. The Committee’s choice of a monetary policy framework is not a short-term choice. The Board does not have plans to re-impose transfer limits but may make adjustments to the definition of savings accounts in response to comments received on the Board’s interim final rule and, in the future, if conditions warrant.
Posted By: John Burnett

Re: Reg D clarification - 10/25/21 09:28 PM

The rule was issued as an interim final rule because the Fed felt it was an opportunity to not only get rid of the limits but also to provide savers who may have been affected by the pandemic added flexibility for account access. It would have taken months to go the standard route of proposal, comment period, review of comments, final rule.

We may see a final rule, and I would bet there won't be any definitional changes in it.
Posted By: Inspector

Re: Reg D clarification - 10/25/21 10:06 PM

Doesn't this final rule as it relates to the reserve requirements effectively remove the six-per-month limits?

govinfo.gov/content/pkg/FR-2021-02-10/pdf/2020-28756.pdf
Posted By: rlcarey

Re: Reg D clarification - 10/26/21 11:34 AM

Inspector - That release lowered the reserve requirements to zero and did not address the transaction limits.