Can we still charge a fee for excess money market transactions even though Federal Reserve eliminated the 6 per month transaction limit?
While the Fed has revoked Reg D, when it comes to excessive withdrawals individual banks are still able to charge fees after a predefined number of debits or withdrawals. The question I have is when a bank charges a fee, should that fee be counted toward that withdrawal number? I am concerned that this is a UDAAP risk.
Can an IRA customer contribute if he or she is 75 and earning income?
During a recent compliance forum I understood the consultant to say that the 7 day notice of withdrawal language needed to be a part of the TISA disclosure – even if it is part of the terms and conditions disclosure. It is not at our bank.
I spoke with a bank manager that has a background in compliance but has been out of the deposit compliance loop for several years. He says that as long as it was in our T&C then we should be fine.
I can’t get what the consultant said out of my head – can you help? Is there a citation that addresses this in Reg DD or Reg D? Maybe I misunderstood?
When is the 2020 FFIEC BSA Exam manual effective?
Do we have to change our Savings Deposits?
On a joint account, Bob or Betty, if Bob makes a deposit and Betty makes a deposit, do we really have to do four part Is
Is a US TIN enough for a NRA on an interest bearing account?
Can my customer waive and RMD for an IRA?
If a customer has in IRA Certificate of Deposit and makes withdrawals within six days of one another, is this a Reg D violation unless a minimum seven day interest penalty is assessed? Is there different treatment if the customer is more or less than 59 1/2?
Prior responses on this site are somewhat contradictory:
Q&A - "Limit of Distributions on IRA accounts" and "IRA Client CD Deposit-Exception to Penalty (Reg D)" both answered by Randy Carey.
In the first he states "Any withdrawals within six days of one another would require an automatic seven day interest penalty under Reg D." There is no differentiation based on age in the response.
In the second he states "Any withdrawal from an IRA is exempt once the person reaches 59 1/2"."
Which really applies?