Funds Availability in Light of Regulation D Changes
On our FREE Deposit Compliance Q&A Forum presented April 28th, there was some discussion as to whether the recent changes to Regulation D will result in savings accounts being subject to Regulation CC.
For purposes of its funds availability requirements, Regulation CC excludes “savings deposits” from its definition of “account”. Regulation CC points to the Regulation D definition of a savings deposit, which still includes the “reservation of right”, or the ability to require a customer to give written notice of a withdrawal at least seven days in advance.
If you remove the “reservation of right”, the account would no longer be a savings deposit and would be subject to the funds availability requirements of Regulation CC. If you continue to maintain the “reservation of right”, your savings accounts would not be subject to Regulation CC’s funds availability requirements.
Did you miss this hour long Deposit Operations Forum? Don’t worry you can still watch the full presentation.
Published
2020/04/30
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Forum 2020 Follow-up
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!