Interpretation of Reg D Number of Transfers Limit

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Question:

I feel that my bank's operations unit has misinterpreted the Reg D provision limiting the number of transfers. They read the cycle to include quarterly statements on savings accounts and limit the six transfers per quarter not monthly. The depositor is permitted or authorized to make up to six transfers or withdrawals per month or statement cycle of at least four weeks.

Answer:

Your bank can impose more stringent limits than the regulation requires. However, you don't have to cap limited transactions at six per statement cycle for accounts with quarterly statements.

Instead, you can permit up to 6 limited transactions per calendar month, statement month or a period of a month's duration that runs from the Nth day of each month to the Nth day of the next month, if statements are prepared every third Nth of the month.

First published on BankersOnline.com 1/23/12