Reg D Limits -When is a Transaction a Transaction?

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Question:

Reg D limits savings account automated/ACH type transactions to six per month. In the case of NSF ACH items returned, does transaction mean transactions attempted or transactions completed? Do items returned not paid (NSF/stop payment) count against the six transactions?

Answer:

If the transaction does not hit the account and get paid, then it is not a transaction for the limitation purposes.

First published on BankersOnline.com 3/17/08