Reg D Customer Allowed Unlimited Withdrawals?

Andy Zavoina: Randy's answer is to succinct for me, but he is correct. Looking at the definition in Reg D which controls this, it says these restrictions apply to transfers, "to another account (including a transaction account) of the depositor at the same institution or to a third party by means of a preauthorized or automatic transfer, or telephonic (including data transmission) agreement, order or instruction, or by check, draft, debit card, or similar order made by the depositor and payable to third parties." The intent is to prevent numerous transactions and that it not "feed" the DDA effectively making this an ATS account, as an example. The key is third parties as well. The rule of thumb is, if it is inconvenient, it is exempt. If the customer has to get off the couch and go to the bank or ATM to get funds, it is inconvenient to them.