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Reg D and Too Many Over-the-Counter Withdrawals

A commercial customer opened a savings account for his commercial account. He was making too many over-the-counter withdrawals from this account monthly, so I (as the officer of the account) was told to close out his commercial savings account because he was violating REG D. Is this true? He only conducted OTC transactions, no EFT or ACHs.

Answer by David Dickinson:If he is coming in the bank (over-the-counter), these don't count toward the six per month.


Answer by John Burnett:Regulation D includes regulatory limits on activity in a savings account that you must impose on your customers. You may impose more restrictive limits if you wish, such as limiting withdrawals of all types per month. If your bank's deposit contract imposes more restrictive limits, you can, as a matter of contract, policy and procedure, close the account, but you should not blame the regulation for your more restrictive rules.

First published on 8/30/10

First published on 08/30/2010

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