Reg D

Posted By: amberleigh

Reg D - 10/11/13 03:03 PM

Are banks required to have a Reg D Policy? We subscribe to sample policies from Sheshunoff, but Reg D isn't included.
Posted By: renniks

Re: Reg D - 10/11/13 07:25 PM

I don't believe you are required. My bank has 52 different policies, but we do not have one for Reg. D.
Posted By: John Burnett

Re: Reg D - 10/11/13 07:54 PM

You need to have a procedure to identify accounts in which the accountholders fail to observe the monthly transaction limits more than occasionally, and to take appropriate action to curb excessive activity in those accounts. Policy? No.
Posted By: manimal

Re: Reg D - 10/11/13 08:38 PM

I agree with John Burnett... a procedure is more than adequate.
Posted By: HuntFish

Re: Reg D - 01/09/14 07:35 PM

I see that you stated "montly" monitoring. Currenlty this is the way that we monitor savings and excessive transactions:
the savings statement will be quarterly, so the montoring is quarterly (allowing only 6 transfers/withdrawals per quarter). If the savings statement is montly (due to EFT - Reg E), then the monitoring is monthly (allowing only 6 transfer/withdrawal per month). Something in the way that said "monthly" makes me think that we need to re-do our monitoring and review each savings account monthly for excessive transactions and forget the quarterly monitoring. Ami I right???
Posted By: HuntFish

Re: Reg D - 01/11/14 04:34 PM

Bump....but i think i know my answer!
Posted By: John Burnett

Re: Reg D - 01/13/14 09:03 PM

Yes. The rule says you have to control activity so that restricted transfers or withdrawals from the savings account don't exceed six in (a) a calendar month, or (b) a statement cycle or similar period of at least four weeks.

If you cycle accounts on a mid-month to mid-month basis, you clearly can use the statement cycle and it will be at least four weeks long.

If you cycle on longer than a monthly basis, as for a quarterly savings account, you can use the longer statement period, but you'd be restricting your customers unnecessarily to 6 limited transactions per quarter. Instead, you should be cutting that three-month period into three parts and monitoring on a basis of a basis of more-or-less 4-week periods (from the 20th of one month to the 20th of the next, as an example).