The Fed never said anything that would prevent a bank from imposing a fee for excess activity in a savings account, before, during, or after the April changes that eliminated the requirement for limits on transfers from them.
Back when there were still limits, what the Fed DID say was that the mere charging of a penalty for excessive transfers would not, by itself, satisfy the requirement for a compliance program designed to restrain depositors from exceeding the limit on more than an occasional basis.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8