Answer:
by Randy Carey:
Since these would be interest bearing DDA accounts, I am not sure what Regulation D violation you would be referring too?
Answer:
by Brian Crow:
If your institution is still offering Negotiable Order of Withdrawal (NOW) accounts, the ownership prohibitions of Regulation D are still in place.
With Regulation Q's repeal in 2011, institutions could begin offering interest bearing checking accounts to for-profit businesses. There is no Reg D violation provided you are offering interest bearing checking accounts to for-profit entities and not NOW accounts.