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Customer Violates Reg D for a 3rd Time

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When a customer violates Reg D for the third time, we take away whatever was abused; such as internet transfers, ACH etc. Can we give what we took away back to the customer or is it gone for good, or do we not take away something and just close the account? I'm not sure what is a best practice.

The best practice is to internally reclassify the account into a interest bearing DDA account. Then you never have to worry about it again. Other than that, it is purely a business decision.

First published on 08/25/2019

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