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#643992 - 11/29/06 04:40 PM Repurchase Agreements & Reg D
LJones Offline
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LJones
Joined: Apr 2006
Posts: 156
Are transfers to a repurchase agreement account from an interest-bearing account subject to the Reg D limitations?

Thank you in advance!

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#644017 - 11/29/06 05:02 PM Re: Repurchase Agreements & Reg D LJones
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,988
FINALLY ABOVE the gnat line
Funds shouldn't be transferred from an interest bearing account into a repurchase agreement for that very reason. Most repos are set up as a daily sweep. The repo isn't subject to Reg. D because it's not insured by the FDIC - it is a security instrument.
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#644248 - 11/29/06 07:35 PM Re: Repurchase Agreements & Reg D waldensouth
LJones Offline
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LJones
Joined: Apr 2006
Posts: 156
Forgive me for my ignorance, but please explain why the repo isn't subject to Reg D because it's not insured by the FDIC.

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#644281 - 11/29/06 07:50 PM Re: Repurchase Agreements & Reg D LJones
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 84,652
Galveston, TX
If the transfer is coming from an interest bearing account and that account is either a savings or MMDA account, the transfer limitation will apply to the account. If you are talking about a NOW account - there are no transfer limitations.

Repurchase agreements are not governed under Reg D, as they are a non-traditional banking product and therefor, there are no transfer limitations on repos. It is really an investment product.
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#644309 - 11/29/06 08:03 PM Re: Repurchase Agreements & Reg D rlcarey
LJones Offline
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LJones
Joined: Apr 2006
Posts: 156
Thanks for the explanation.

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#644491 - 11/29/06 11:17 PM Re: Repurchase Agreements & Reg D LJones
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Originally Posted By: LJones
Forgive me for my ignorance, but please explain why the repo isn't subject to Reg D because it's not insured by the FDIC.


It isn't that they aren't insured. It's that they are not deposits.
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#652155 - 12/14/06 05:27 PM Re: Repurchase Agreements & Reg D John Burnett
tjbanker Offline
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Joined: Jun 2002
Posts: 310
We are looking at the possibility of offering a repurchase agreement with nightly sweeps for a corporate customer. I am looking for a sample repurchase agreement and daily notices. Would someone be interested in sharing a copy of what they use or direct me to a web address that would have a sample? Thank you!!

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