Compliance Blog

The Federal Reserve is seeking comments on a proposal that would, among other things, end the three/six distinction for regulated transfers under Regulation D. 

Here's a NAFCU Today article about the proposal.
Here's a link to the Fed proposal.

In the words of the Fed:

The second of the proposed substantive amendments would eliminate the provision in the “savings deposit” definition of Regulation D limiting certain kinds of transfers from savings deposits to not more than three per month. As a result, all kinds of transfers and withdrawals from a savings deposit that must be limited in number per month would be subject to the same numeric limitation of not more than six per month.

Food for thought: In my humble opinion, this would be a move in the right direction.  Although for years NAFCU has advocated the entire elimination of the six-limit transfer limitation in favor of a more reasonable, and hopefully higher, number of allowable transfers, erasing the three/six distinction should make transfers easier to track for credit unions.  But should this be approved, you'll need to review your disclosures where you address Reg D's limitations to ensure their accuracy. 

NAFCU is preparing comments regarding this rule.  Please feel free to email Pamela Yu at pyu@nafcu.org with your feedback.