Reg D: If a wire transfer request is delivered by messenger, does it count against the limit?

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Question:

Reg D Limits: (Scenario: MMDA i/n/o "Deposit Broker, as Agents for others" for which daily settlements are effected.) Are wire transfers from the MMDA limited to 6 per month when the request to wire funds is hand delivered to the institution by a messenger from the deposit broker?

Answer:

One of the exceptions to Regulation D transaction limits is the withdrawal made by (the customer's) messenger. Given the hypothetical you've posed, I think these transactions are not subject to the limits in Section 204.2(d)(2) of Regulation D.

But you should be certain the bank is not paying for the messenger.

[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 5/06/02