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Trustees, Reg D, and Third Party Checks

Answered by: 
John Burnett

Question: 
How is a trustee from a law firm treated with regard to Reg D? The trustee writes a check on a trust account payable to the trustee's firm? Is it a third party check? The trustee is an account holder at our bank as well.
Answer: 

The trust is an entity. The law firm is a separate entity. The payment is a third party check, subject to the three/month limits in Regulation D if drawn upon a savings/MMDA account

[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 2/17/03

First published on 02/17/2003

Filed under: 
Compliance
Filed under compliance as: 
Checks
IT
Transfers

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