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NAFCU President and CEO Dan Berger, in a letter sent Friday, urged the Federal Reserve Board to consider removing the limit imposed by Regulation D on consumers' ability to freely transfer money between savings and transaction accounts. Berger pointed to the coronavirus as a reason for the board to take such a proactive measure.

"Doing so would alleviate potential stress on household liquidity during times of uncertainty, make it easier for consumers to manage their personal finances, and alleviate operational burdens placed on credit unions that must enforce the limit," Berger wrote.

Under Regulation D, consumers are limited to six transactions per month; once that limit is reached fees can be assessed or the savings account can be reclassified as a "transaction account." NAFCU has long argued that the transaction limit is "unreasonable" and should be eliminated.

In addition to hindering credit unions' members' ability to manage their finances, the limit also creates operational burdens for credit unions that must mail disclosures, close or convert accounts, and respond to complaints about the limit.

Berger argued the coronavirus could potentially exacerbate these issues if consumers have unexpected healthcare expenses.

"Any public perception that funds are not available in such a scenario would pose serious reputational risk not only to individual financial institutions but to the financial sector as a whole," Berger said.

NAFCU will continue to advocate for the Fed to reform Regulation D so it better reflects modern monetary policy.