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#1144230 - 03/12/09 07:02 PM RDC Subject to Reg D
CynthiaParker Offline
Junior Member
Joined: Apr 2006
Posts: 45
Midwest
Issue: Customer is set up with remote capture deposit, they want to write a check to themselves drawn on an account subjecto to Reg D transaction limitations, process it through the RDC system, then deposit the funds to their DDA account, all at the same bank. They want to know if this type of transfer would be exempt from limitations.

My initial thought is it's not dissimilar to online banking, it's electronic and it's convenient, therefore, it counts.

Experience with this? Input please?
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Deposits and Payments
#1144256 - 03/12/09 07:21 PM Re: RDC Subject to Reg D CynthiaParker
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
It's hard to argue with the way you see it. Of course the customer sees RDC as an extension of your bank teller line. You know that regulators don't see it that way, because they've used the fact that the images aren't deposited at a branch as the reason Reg CC doesn't apply.

I suggest that your bank should consider that type of transfer as subject to the Reg. DD limits.
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#1671072 - 02/29/12 03:22 PM Re: RDC Subject to Reg D John Burnett
LJones Offline
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LJones
Joined: Apr 2006
Posts: 156
Anyone aware of the release of guidance on the answer to this original question since this 2009 discussion?
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