If you classify them as transaction accounts and they don't meet the definition of savings accounts under Regulation D, they become transaction accounts, either DDAs or NOWs. And that makes them subject to Regulation CC, regardless of whether you label them savings accounts for your customer. I see customer confusion in the making.
Your call report preparation is also affected.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8