Does your Bank have a Reg J Policy, or perform testing/monitoring for compliance with Reg J?

I am struggling to piece together the components of Reg J that are applicable to my Bank (FDIC-supervised). It appears the most likely component that is applicable is Subpart B, as it incorporates the primary purpose of the provisions in Article 4A: to define the rights and obligations of the parties to wire transfers or funds transfers.


If anyone can offer a blueprint or guidance here, that would be greatly appreciated.

Why would you need either a policy or procedure specific to Regulation J. I have never seen one in 40 years of banking.

Good question. My concern is that I don't have an answer as to why we would need a Reg J policy, but I also don't have an answer as to why it's okay not to have one.

Is it that the requirements of Reg J are not actually applicable to Banks?

Depends on whether or not you clear checks through the Federal Reserve. But even then, you would not have specific procedures labeled Reg J. No more than you would have specific procedures for UCC 3, 4, 4a, etc. If you have written procedures that address what you do in collecting, returning and disputing items, I would hope any pertinent laws and regulations are already built into them.

Okay - so it sounds like the requirements of Reg J would most naturally be baked into a Wire Transfer Policy or Procedural document.