With the Federal Reserve Board making changes to the Regulation D requirements, credit unions, CUNA and Leagues have seized the opportunity to voice their support for a revision to the outdated six-per-month transfer limitation. Under the current Reg D (§204.2(d)(2)), members are limited to the number of transfers and withdrawals from savings accounts unless it is conducted in person, by mail or at an ATM.
In numerous submitted letters, commenters encouraged the Board to consider online and phone transfers among accounts at the same institution as methods to exclude from the transfer limit. CUNA suggested the Fed either raise this limit or abolish it entirely.
"Due to technological advances, consumers can now make payments and transfers online, via telephone, at point-of-sale terminals, and via Automated Clearing House (ACH) transactions," and these advances have enabled financial institutions "to deliver financial services to consumers conveniently and at lower costs." The six transfer limitation "unreasonably restricts consumers from being able to easily access their own funds for their own use," CUNA said.
The League noted in its comment letter that modernization of Red D would “represent a meaningful change for consumers and financial institutions, including credit unions alike.” In closing the letter, the League remarked that “a proposal to lift this transfer restriction, which is within the Board’s rulemaking authority, would have pervasive support and presents the Board with an opportunity to provide meaningful regulatory relief.”
While the Fed was not making revisions specifically related to transfer requirement, this was a chance for industry experts to voice the support for a much needed change.
To view all of the comments to the Federal Reserve Board, click here.