Yes, Brian...I agree....that is why I'm having a hard time with this....

Thanks so much, John....

To be fair with that instructor, Compliance504 (and it could have been me), the Reg CC question was "out there" for several days before the Fed added the clarification to its FAQ on Savings Accounts. I remember wondering about any Reg CC implications soon after the definitions in Regulation D were announced.

It wasn't you, John....in this webinar, the FAQ clarification on Reg CC was included in the materials...but the advice given was to keep withdrawal limitations on savings accounts...because without them you'd have transaction accounts.....

So it left me confused on what to advise Mgmt.....

For now, we are just going to continue what we've been doing.....we understood that there was no notice requirement and documented that we would notify customers once "permanent" changes were made.....

However, since we don't know how long it will be for the final rule....I'm suggesting that we do now notify customers that until further notice, enforcement has been suspended....

So opening this back up on the subaccount disclosure...I had read the conversation on this back in May but our bank was continuing doing the FR2900 under the assumption it was temporary. Now that it has been clarified that is permanent, I have a question on our online account opening disclosure. It is an all in one disclosure and includes the subaccount organization verbiage. For it to be removed, the vendor that created it states it could take 4-6 weeks. Could we continue opening accounts with the current disclosure? How big of an issue would this be?

Since the Board eliminated all reserve requirement in March 2020 - of what value is this program anymore besides totally confusing both your employees and customers with it? If you are still paying residual income to your vendor that helped set up this scheme - you might want to take a real close look at your contract. I highly doubt you will ever see the Federal Reserve use this sort of reserve requirement again under the more current and updated monetary policies.

If you are eliminating the program - then send a change of terms notice to all existing accountholders and include that with your current account opening disclosures until the contract can be amended.

I don't think anyone even understood what it was and why we even had to give it out to begin with. It didn't affect the customer in any way, just something that adjusted when we did our call report.

When the change to Reg D came out last year we stopped monitoring our accounts for excessive withdrawals. We also suspended the debit item charge that we charged when they exceeded a certain number of withdrawals. I put the statement on our TIS disclosures and on our statements that "Due to the Covid 19 Pandemic the bank was suspending the debit item charge effective 5-1-2020 until 3-31-2021. Since that time has lapsed we want to start charging again for the exceeded transactions. My question is do I need to send a 21 day or 30 day notice to all Savings and Money Market customers that we will be charging again and have to wait until that time is up before we can charge them?

Thanks!

Technically probably not, but I would have put another statement message reminding your customer that the fee was going to resume on 04/01 as originally communicated.

Thanks Randy!

We are debating whether we should start monitoring/charging this fee again and wanted to see how many banks are charging vs. not charging

We no longer monitor for excessive withdrawals. I tried to vote on your poll but it states I am not allowed to vote in polls...

Polls no longer work on BOL. What are you trying to accomplish with reinstituting the fee?

Certain regulators might consider this one of the "junk fees" they've been crusading against if the bank is one they examine for consumer compliance.

Randy - I am assume generate revenue. John - I agree and the process is manual. I have asked enough questions to determine the labor and postage is more expensive than the fee income so I'm kind of confused we are still discussing this.