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NAFCU updated its Final Regulation Alert to include clarification from the Federal Reserve that it has no plans to re-impose the six-per-month transfer limit between savings and checking accounts under Regulation D, which was eliminated by a recent interim final rule. This clarification came following NAFCU President and CEO Dan Berger's request that the Fed provide further information on its rule.

NAFCU’s updated Final Regulation Alert explains the Fed’s update to its online FAQs indicating that there are no plans to re-impose transfer limits. However, the board stated it “may make adjustments to the definition of savings accounts in response to comments received on the Board’s interim final rule, and in the future, if conditions warrant.”

The association has long advocated for the transfer limit to be eliminated and doubled down on its advocacy amid the coronavirus pandemic.

In addition, the updated Final Regulation Alert explains the addition of FAQ  No. 13 that provides clarification on the interaction between the Regulation D amendments and Regulation CC, concluding that the amendments do not result in "savings deposits" now being covered by Regulation CC.

NAFCU's Final Regulation Alert also highlights key changes to the rule and addresses:

• the context for the relief in terms of recent Federal Reserve actions to eliminate reserve requirements; and
• reporting flexibility for institutions that suspend the six-transfer limit on a "savings deposit."

The changes to the transfer limit became applicable April 23, and the amendments to the regulation will become effective once published in the Federal Register. There is a 60-day comment period following posting in the Federal Register; comments are due to the Board on June 29. Credit unions are encouraged to send comments to NAFCU Senior Counsel for Research and Policy Andrew Morris at amorris@nafcu.org.

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