Answer:
Ordinarily, if the bank's courier picks up transfers from a savings or MMDA, those transactions would be subject to the limitations in Reg D. However, you have indicated that you have a mobile branch license. To the extent that the branch travels to the customer, I believe that the transfers are made "in person," and therefore are not counted. However, if it's not a branch but simply an employee visiting the customer then transactions would not be "in person," and you would have to count them. Make certain that you understand the fine line between the branch and any other visit to the customer.
First published on BankersOnline.com 4/20/09
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