Answer by Andy Zavoina:
Yes. This would be a convenient way to circumvent the controls Reg. D places if these were unlimited.
Answer by John Burnett:
It is one of banking's little ironies that at the same time we are encouraging our customers to shift to e-transactions, we continue to be hobbled by a decades-old regulatory framework that runs counter to our goals.
It's sort of like inviting your customer to try out your bank's new Maserati, but adding a governor to limit its speed to 35 mph.!
[Editors Note:As of 7/2/09, the separate limit of three per month for checks, POS debit card transactions, etc., has been eliminated, and those transactions are now only subject to the 6/month limit that applies to other restricted transfers and withdrawals.]
First published on BankersOnline.com 10/6/03