FRB Eliminates Six-Per-Month Regulation D Limit

On Friday, April 24, 2020, the Federal Reserve Board announced an interim final rule amending Regulation D to immediately delete the six-per-month limit on convenient transfers from the definition of savings deposit and allow financial institutions to immediately to suspend enforcement of the six-transfer limit. Compliance Resource has been anticipating this amendment and is pleased to see this announcement, as this action brings relief to customers needing to easily access savings deposit funds during the pandemic.

The Interim Final Rules states:

“Because of the elimination of reserve requirements and because of financial disruptions related to the novel coronavirus, the Board is amending Regulation D, effective immediately, to delete the six-transfer limit from the “savings deposit” definition. This interim final rule includes deletion of the provisions in the “savings deposit” definition that require depository institutions either to prevent transfers and withdrawals in excess of the limit or to monitor savings deposits ex post for violations of the limit. The interim final rule also makes conforming changes to other definitions in Regulation D that refer to “savings deposit” as necessary.

The interim final rule allows depository institutions immediately to suspend enforcement of the six-transfer limit and to allow their customers to make an unlimited number of convenient transfers and withdrawals from their savings deposits. The interim final rule permits, but does not require, depository institutions to suspend enforcement of the six- transfer limit. The interim final rule also does not require any changes to the deposit reporting practices of depository institutions.”

The FRB included FAQs related to the amendments in the Interim Final Rule and also made them available on their website.

The FRB press release is available here. Visit our Pandemic Forum to discuss this and other pandemic related issues.

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