[Not a Fan]

I have a Regulation D, Excessive Transaction question. I wanted to see if we had any other options in handling this. In the past, when we were an OTS supervised bank, they were ok after three letters to the customer if we turned off the interest function on their savings account. Now, we seems to get quite of few monthly offenders. I have always hoped our Data Service Provider could just change their savings to a non-check issuing checking account but they can’t cross over and change parameters from major to minors (savings to checking). Does anyone else have a different option other than having the customer close their savings account and open another checking? Several have multiple ACH’s coming out and it creates issues. I’m just looking for a simpler more effective way of handling this if there is one. Thanks!

[rcooper]

If more than six transfers/withdrawals are continually permitted it can’t be classified as a savings account on your system. If a customer continues to exceed the transaction limits then you either need to prohibit the transactions (if you want leave them in the savings account) or close the account and open a transaction account. Are you sending notices or contacting the customer in some way letting them know they are exceeding the account limitations and that if they continue to do so what action you will be required to take? Usually these steps will deter many customers from continuing to exceed the limits.

Here a link to Reg D (see 204.2(d) and footnotes): https://www.gpo.gov/fdsys/pkg/CFR-2016-title12-vol2/pdf/CFR-2016-title12-vol2-sec204-2.pdf

[Not a Fan]

Yes, we do send notices to make them aware of the requirements. It helps some, but many do not even read their mail. We do close the accounts or block certain transactions but just wanted to know if there were an easier way. Thanks!

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