Reg. D IFR 2020 Apr – Q.10. May a depository institution that suspends enforcement of the six transfer limit continue to charge… fees when savings deposit customers make seven or more convenient transfers and withdrawals in a month?

Compliance > Regulation D - Reserve Requirements
Q:   Suppose that a depository institution currently has policies or provisions in their savings deposit account agreements pursuant to which the depository institution charges fees to savings deposit customers for transfers and withdrawals that exceed the six transfer limit. May a depository institution that suspends enforcement of the six transfer limit continue to charge these fees when savings deposit customers make seven or more convenient transfers and withdrawals in a month?
 
A:  Regulation D does not require or prohibit depository institutions from charging their customers fees for transfers and withdrawals in violation of the six transfer limit. Accordingly, the deletion of the six transfer limit does not have a direct impact on the policies or account agreements of depository institutions that charge such fees to their customers.
 
 
This information can be found in the FRB’s Reg. D Interim Final Rule that was published on April 28, 2020 with a stated effective date of April 24, 2020, here - https://www.federalregister.gov/documents/2020/04/28/2020-09044/regulation-d-reserve-requirements-of-depository-institutions
 

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