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Reg D Limits & Check Withdrawal Phone Transactions

Question: 
According to Reg D, under the sixtransaction limit, are check withdrawals to the accountholder transacted through an automated phone system included?
Answer: 

Answer by Jim Bedsole:

Yes they are.

Answer: 

Answer by Andy Zavoina:

If the check is made payable to the accountholder and mailed to them, it would not. If that check is payable to a third party or was deposited to another account of theirs at your bank, it would.

Ref. 204.2(d)(2) Because a third party does not seem to be involved in the original question, this would be an inconvenient way to withdraw funds. A general and unscientific method of determining what is limited or not is if it is convenient to the customer. Convenience counts, inconvenience doesn't.

[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 BankersOnline.com 06/9/03

First published on 06/09/2003

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