REG D- Transfers made by email

We have a customer that wants to set up a Money Market account and wants to make transfers via email (not through the the typical internet transfer process, but an actual email to a bank employee). Any restrictions on the # of transfers they can make a month or statement cycle? We are wanting to treat it like a telephone transfer, which would not have restrictions. What do you think?

If they email or call and you transfer the funds to another account (DDA) of theirs, this would be a sweep type arrangement and would be limited. If you send them a check it wouldn't count.

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We are wanting to treat it like a telephone transfer, which would not have restrictions. What do you think?

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I think you should re-read Regulation D, section 204.2(d)(2). Transfers made by telephone are most certainly covered by the restrictions, unless the instruction is to send the withdrawn funds by check payable to the customer.

Email is, I believe included within the phrase "telephonic (including data transmission) agreement, order or instruction" found in that section of the regulation. Unless the instruction from the customer were to "send me a check," you should count each such transfer in the six per month limit.