Answer:
by John Burnett:
Savings accounts as defined in Regulation D are excluded from the definition of "account" in Regulation CC. Take a look at the wording of the "account definition." It ends with "but the term does not include savings deposits or accounts described in 12 CFR 204.2(d)(2) even though such accounts permit third party transfers." That is true without regard to whether the savings account is subject to transaction limitations.
Also, review FAQ #13 at https://www.federalreserve.gov/supervisionreg/savings-deposits-frequentl....
Answer:
by Randy Carey:
Reserving the right to a 7-day notice of withdrawal is what makes it a savings account and not a demand deposit.
204.2(d)(1) Savings deposit means a deposit or account with respect to which the depositor is not required by the deposit contract but may at any time be required by the depository institution to give written notice of an intended withdrawal not less than seven days before withdrawal is made, and that is not payable on a specified date or at the expiration of a specified time after the date of deposit. The term savings deposit includes a regular share account at a credit union and a regular account at a savings and loan association.
Answer:
by Randy Carey:
How did Regulation CC get introduced into this question?
Answer:
by John Burnett:
When the Fed eliminated the savings transfer limits and reserve requirements, they gave banks the okay to report savings accounts as transaction accounts in their periodic reports of reserve balances. Peoples starting suspecting a nexus to Reg CC's definition of "account," which is pretty broad, fearing that savings accounts would now be "accounts" for Reg CC.
But the Fed carefully confirmed that savings accounts and other accounts in 204.2(d)(2) are not "accounts" under Reg CC.
print
share