Skip to content

MMDAs Opened by Internal Trust Department

Answered by: 

Which letter regulations apply to money market deposit accounts (MMDAs) opened by an internal Trust Department that also manages/invests the account activity via an agreement with the trust owner and the Trust Department? [ex. Reg O, Reg DD, Reg D] The customer does not transact on the account and the Bank sponsored Money Market is a product of an omnibus Internal Bank DDA Account.

Where an account is opened and who manages it is secondary to what the account really is. A Money Market is a type of savings account defined by the FRB's Reg D. Once on the page, search on "money market."

When you have an account meeting this definition, the rules apply. Reg DD will apply as to disclosures and conditions for consumer accounts and Reg O is typically a lending related regulation but is impacted by deposit products in overdrafts and in some cases interest payments to insiders based on the deposit account.

Trust account requirements can add another layer of requirements to these deposit accounts. I cannot speak to them, however.

First published on 06/03/2018

Filed under: 
Filed under compliance 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