Answer:
Not by regulation. This requirement went away in April 2020, when the Fed realized a COVID-beset public needed more frequent access to their savings accounts during the pandemic. They removed the cap by changing the definition of “savings deposits” in Reg D. They reserve the right to change it back in the future, but that hasn’t happened yet.
While you no longer have to monitor for excessive savings account withdrawals, you can still impose your own limitations and charge a fee for withdrawals exceeding 6/month. This isn’t a Reg D issue, though, it is a Reg DD disclosure matter. Make sure you keep them straight!
Baffled? The interplay between Reg D and DD is like that. Tune into the upcoming webinar “To Tell the Truth: TISA, Reg DD and Reg D” on January 17, 2024 to gain clarity!
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Learn more about Rebekah Leonard’s To Tell the Truth: TISA, Reg DD and Reg D webinar.
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