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Online Banking Transfer Limits

If a customer performs transfers between his MMDA and his checking accounts using the bank's "on-line banking" product and exceeds the preauthorized limit of 6 transactions, would he be considered in violation of the reg? I would think that because he is performing the transaction himself, it would not exceed the limit (similar to using an ATM card at an ATM machine). Have you heard anything from the regulators about this?

Answer by Andy Zavoina: These are not the same as going to an ATM. They are the same as a telephone transfer, however. So they are limited to 6 and you must enforce the Reg. D restrictions on these convenient transfers.

The rule of thumb is, if it is convenient, it counts.


Answer by John Burnett: Think of an ATM as a branch of the bank (even if it's someone else's ATM). Then making the transfer at the ATM is the same as making in person.

Everything else is more convenient than having to get off the "seat of one's pants" to go to the bank or ATM. So everything else counts toward the limits (with very technical exceptions).

[Editors Note:As of 7/2/09, the separate limit of three per month for checks, POS debit card transactions, etc., has been eliminated, and those transactions are now only subject to the 6/month limit that applies to other restricted transfers and withdrawals.]

First published on 11/3/03

First published on 11/03/2003

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