Reg D violations--I know what regulators could do (CMP, make you refile call reports, recalculate reserves, etc). Is there any info out there about what has been done lately? Anyone know of any recent CMPs for such violations or any other stiff regulator actions? Anyone recently been cited for not monitoring excessive transactions?

I've never seen a CMP for a Reg D violation. Several years ago I saw 2 banks that were not monitoring debit limits at all. The FRB (in both cases) made them refile their FR 2900's and CALL reports for 2 years.

Anyone willing to share any recent (last couple of years) citations for Reg D, this would be helpful. You can PM me if you would like.

Refiling the FR 2900 can result in reserve deficiencies for some of the reserve periods in the two-year period. Deficiency penalties are covered in section 204.7 of Regulation D. If a bank's entire $200 million portfolio of MMDAs, for example, were reclassified as transaction accounts by the bank's regulator, and the reserves of the bank were therefore consistently $20 million low (that would never happen, but for purposes of illustration ...), and if the discount rate were consistent over the period at 6.25%, you could have a hefty $2.9 million reserve deficiency penalty that would never be publicized, except in SEC and similar filings for publicly-held institutions.

The FR Board can waive penalties except in cases of gross negligence or disregard. They can also assess CMPs, although I, too, have never heard of one being levied.