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Changing Acct. w/o Permission (Reg D Violations)

Question: 
When monitoring accounts for Reg D violations and an account change is required, is it permissible to close a savings account and open a checking account with the funds without the customer's consent?
Answer: 

Answer by Kathleen Blanchard: The bank should monitor activity and send notices to the customer regarding the limits and repercussions for exceeding those limits. When it reaches the point that the account must be closed and funds moved to a different account, the bank does not need permission from the customer to do so. The customer has continued to violate the regulation despite notice. Usually a final notice is sent that the account is being changed and the funds are moved.

Answer: 

Answer by John Burnett: If you do open a different account or convert the existing account (as you may be able to do with an MMDA), make sure you provide new account disclosures.

First published on BankersOnline.com 3/26/12

First published on 03/26/2012

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