If an IRA client (over 59 1/2) receives an automatic IRA distribution from their retirement CD, and then comes to a branch and makes an additional over the counter withdrawal from the same CD within six days after the automatic distribution, is that considered a violation of Reg D?
We are debating this due to the fact that the footnote in the Reg D language, that indicates the exceptions to charging a penalty, was placed after the first statement about CD deposits. It was not placed after the next statement regarding partial withdrawals. So do the exceptions only apply to withdrawals made following the deposit, or do they apply to partial withdrawals as well?
We offer Super Checking accounts that pay interest. Do the eligibility rules under Regulation D apply to this type of account?
Can we charge a Money Market account a per item fee for each item that exceeds the allowable 6 withdrawals per month?
Our bank allows ATM debit transactions from savings accounts, direct deposits to savings accounts, and telephone transfers from savings to other accounts.. As far as Reg CC funds availability holds are concerned, are we allowed to put holds on savings accounts since we allow these kinds of transactions? Have we allowed these savings accounts to become transaction accounts?
My client made 12 withdrawals in person from his money market. I thought the in person withdrawals did not count as a qualified withdrawals. Are we allowed to charge him fees?
Are we allowed to set up automatic internal transfers from a passbook account?
With regard to Reg. D, I was always under the impression that a single member LLC could have an interest bearing checking account. Can you add anything to that?
Under Reg D do you have to send out a notice or can you email the customer making them aware of the excessive withdrawals.
What is the difference between a NOW account and an interest bearing business checking account and what entities can open a NOW account?
Can an ambulance association have a NOW account. Is an ambulance association considered a public fund account?