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Reg D Account Reserve Issues

Answered by: 
John Burnett
Richard Insley

Question: 
When a non-transaction account exceeds it's sixth transaction that account is to be reclassified as a transaction account. Does the entire balance on that account then become reservable or just the dollars of the transactions exceeding the sixth transaction? How is the unused portion of the balance calculated for reserve purposes?
Answer: 

Answer by John Burnett:Entire accounts are classified for reserve purposes, not parts of them. In some banks, sub-account techniques are used to split a single account into a transaction account and a savings account for Reg. D purposes. In such a case each sub-account is considered a single account when reporting for reserve purposes.

Answer: 

Answer by John Burnett:If your savings and MMDA customers exceed the limits because you are not policing the portfolion adequately, the entire portfolio is exposed to reserve requirements, not just the current offenders.

First published on BankersOnline.com 11/20/06

First published on 11/20/2006

Filed under: 
Compliance
Filed under compliance as: 
Reporting

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