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Reg D Limits - One Owner Multiple MMDAs

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Question: 
If a customer has multiple MMDA accounts, all with the same titling, do the Reg D transaction limits apply to each account or to all of the accounts combined/per customer? Would the answer be different if the accounts have different titling, such as one having individual ownership and another having two owners?
Answer: 

The limits apply to the individual account. The customer could make transfers up to the regulatory limit in each account. That said, be very careful. The Federal Reserve has made it clear that a bank cannot set up multiple accounts or promote the practice for the purpose of skirting the transaction limitations. I interpret that to mean that your examiner would expect you to rein in a customer who decided on his own initiative to set up multiple MMDA accounts if it is apparent that the only reason for the multiple accounts is to skirt the limitations.

[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 7/07/08

First published on 07/07/2008

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