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Reg D Excessive Transfers Purposes (Savings Acct.)

Question: 
For Reg D excessive transfers purposes from savings account, can a bank choose to use calendar month for one customer and statement cycle for another customer when both have the same account type, such as a money market deposit, so long as we use this consistently per customer?
Answer: 

by David Dickinson:

You could, but why? Although there's no "fair deposit" regulations there are Fair Banking rules and guidance. I think you're asking for trouble when you treat people differently. If anyone can draw a correlation between these customers and a protected class, you've opened a mess. Why not use statement cycle for all customers. If the statement cycle ends at the same time as the month end, that's fine.

Answer: 

by Richard Insley:

Special handling means additional cost. What's the reward that justifies this unnecessary expense?

First published on 08/05/2018

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