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Reg CC Availability Holds-Savings Accounts

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Question: 
Our bank allows ATM debit transactions from savings accounts, direct deposits to savings accounts, and telephone transfers from savings to other accounts.. As far as Reg CC funds availability holds are concerned, are we allowed to put holds on savings accounts since we allow these kinds of transactions? Have we allowed these savings accounts to become transaction accounts?
Answer: 

Only the telephone transfers would create the possibility of exceeding the transfer limits in Reg D section 204.2(d)(2) for savings accounts, and your bank is responsible for enforcing those limits. Unless you are in a state like Massachusetts that extends the scope of Reg CC to include savings accounts and MMDAs, you don't need to include them.

Some banks have included savings accounts in their Reg CC coverage by choice. It's not a requirement in most states.

First published on 05/06/2018

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