Update on Regulation D Changes and Reg CC
The Federal Reserve has updated its Regulation D FAQs to address a couple of burning questions which resulted from their recent removal of the six debit/transfer limit for savings accounts.
First off, FAQ # 3 clarifies that this is not intended to be a temporary change:
The Board does not have plans to re-impose transfer limits but 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.
FAQ #13 addresses any impact to Regulation CC:
…the recent amendments to Regulation D did not result in savings deposits…now being covered by Regulation CC.
Ultimately, we believe this means that if you continue to classify savings accounts as savings deposits (e.g., on your FR2900), the Regulation D change does not mean those accounts are now covered by the funds availability requirements of Regulation CC. However, if you change the classification from savings to transaction accounts, those accounts likely would become subject to Regulation CC’s funds availability requirements.
Need a refresher on the Regulation CC requirements? Be sure to check out our webinar, Regulation CC, which is available now On Demand. Learn the ins and outs of case-by-case and exception delays and the changes coming July 1, 2020!
Published
2020/05/25
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!