Skip to content

Merchant Capture Device - Reg D Transaction Limits

Answered by: 

Question: 
In your article on Reg D, <a href="http://www.bankersonline.com/compliance/gurus_cmp080502o.html">Transfer of Funds: Do sweeps count against the transaction limit?</a>, you pointed out unlimited transactions between accounts at the bank, done at an ATM, in person, made by mail and Direct Customer Contact. Now where does the merchant capture device fit in this picture, since you have basically taken the bank to them with direct access to move money between their accounts. It seems the customer is standing in front of a piece of equipment very similar to an ATM. Should these transactions count?
Answer: 

Yes, these transactions count, although the regulation is falling behind the times in specifically addressing some of this new technology. If you are talking about a merchant capture device that converts checks to an electronic image that is then processed as a deposit by a bank, the fact remains that this transaction began as a check payable to a third party and would be limited to three such transactions per month or statement cycle.

First published on BankersOnline.com 1/07/08

First published on 01/07/2008

Filed under: 
Filed under compliance as: 
Filed under technology as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics