I tried searching previous posts for this question but came up empty as I did with research on Kirchman.

If we have a limited liability corporation with a Money Market Savings account and they use Internet Banking to transfer funds from their money market account to their checking account does this count under Reg D? This would not be an automatic transfer, the customer makes the transfer each time.

I'm thinking it does count but others in my shop say no. Telephone transfers count, but ATM transfers don't. Internet banking is somewhere in between.

Thank you so much for all your previous help. I don't post a lot but I read whenever I can and try to learn.

Jean,

I see these as needed to be counted as part of the 6 preauthorized, automatic or telephone transfers per month (with no more than 3 of the 6 transfers made by checks to 3rd parties). I believe the Internet transactions or faxes are considered under the "telephone" limitation referenced above. Good luck convincing the office "doubters".

I would agree that these count towards the 6. I don't have a particular cite, but I know that came up here and we decided to count them. We go by the basic rule of thumb - If you can sit at home on your butt to do it - it counts towards the 6. If you have to actually get up, get dressed, and go somewhere to do it, it doesn't count. In a nutshell.

Look at the definition of Savings deposit in the Regulation. Section 204.2(d)(2) says:

"... the depositor is permitted or authorized to make no more than six transfers and withdrawals ... to another account (including a transaction account) of the depositor at the same institution or to a third party by means of a preauthorized or automatic transfer, or telephonic (including data transmission) agreement, order or instruction, ..."

I believe that portion that refers to "including data transmission" would refer to Internet Banking transfers. Further down in the definition it explicitly exludes ATM transfers from the limitations.

Thank you. I like your definition. You're right -- I just hadn't thought of it that way. In person and messenger are "free".