Reg D - excessive withdrawal

A quick question for Reg D issue: if customer comes into the bank and transfers from his personal money market account to his business money market (it is a Corp. and he is the secretary on the account), does this subject to Reg D?

Thanks.

If the customer did the transaction face to face it is not subject to the Regulation D Requirements.

Another question on Reg D excessive withdrawals.
Would a debit card on a money market account used at a merchant's POS be a COVERED tranfer? and only 3 of these per month?

Another question on Reg D excessive withdrawals.
Would a debit card on a money market account used at a merchant's POS be a COVERED tranfer? and only 3 of these per month?

Yes. Only 3/month, since it is a POS.

Thanks, David. What if customer comes to the bank and writes a check from his money market to another account holder's business account of the bank?
Thanks.

IMHO that would count in the "3 bucket."

Question...we have a customer that is a repeat offender in excessive transactions on his Money Market...we've exhausted the 3 letter cycle we normally go through, and have contacted the account officer. The officer does not want to move the customer to another account...what are the regulatory risks to the bank if this is not properly addressed? CMP's? Reserve adjustments?

Complete terror.

Seriously, you'd run the risk in the extreme of having your portfolio (not just that account) classified as a DDA product. So lets go back X months or years to the beginning of the problem and recalculate the reserves you should have had. Oh, looks like you were short based on all these new DDA accounts. That could be a penalty. It is certainly a nightmare.

I heard once of a bank where the examiners were considering making the board pay the bank back the interest that was paid on these now DDAs. (I told my board that and had complete cooperation in this matter.)

Basically, it isn't worth it. At the very best you'll tell your examiner that you don't care about that law and you'll accept whatever penalty they choose.

The net, net, net is that it isn't really up to the bank or its officer to decide which laws and policies you decide to follow today.

Don't you love officers that don't want to follow the law?

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