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#1954068 - 08/18/14 05:12 PM saving/MMDA accounts classified as transaction
river girl Offline
Diamond Poster
Joined: Nov 2004
Posts: 1,005
If we classify our savings and mmda accounts as transaction accounts under Reg D and allow unlimmited debit card transactions, does this flow over to any other regulation and classify these types of accounts as transaction accounts?

I read through Reg CC and it specifically excludes savings deposits so I don't think we need to worry about it (and our funds availability disclosure accurately excludes savings accounts).

Any other reg. that I need to research that limits by "transaction" account?

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#1954857 - 08/19/14 08:09 PM Re: saving/MMDA accounts classified as transaction river girl
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
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

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#1954986 - 08/20/14 12:54 AM Re: saving/MMDA accounts classified as transaction river girl
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 85,380
Galveston, TX
And your reserve requirements.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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