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Reg D - Deposit in Remote Deposit Capture Machine

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Would a money market check deposited into a checking account of the same business customer through a remote deposit capture machine count towards the Reg D transaction limitations? I know that ATM and in person deposits of the same sort are not counted, but internet transfers are and I'm not sure which situation would apply here.

I continue to marvel at the twists and variations that people dream up and often wonder whether someone is out there trying to concoct the most convoluted scenario ever presented to challenge some of these regulations! As strange as this question seems at first glance, it represents a possible real-life situation. Obviously, the Federal Reserve staff has not yet opined on your question. That leaves its examiners and the other regulators, plus the rest of us, with nothing but our wits and some educated guesses.

Here are my thoughts, for whatever they might be worth: I consider a remote deposit capture "machine" the functional equivalent of a standard bank deposit, in that the images of the checks in question are transmitted to the depository bank for deposit and collection. Therefore, I'd use the night deposit paradigm and consider this a form of "in person" transfer, not subject to the limitations on transfers imposed by Section 204.2(d)(2) of Reg D, but, we must all realize that the question you have posed may certainly be capable of being interpreted differently.

[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 10/23/06

First published on 10/23/2006

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