NCCUL Headline Stories

Regulatory Advocacy: Regulation D Proposal - An Opportunity for Change?

Posted on December 1, 2011

We are all familiar with the hindrance of Regulation D in its six-per-month transfer or withdrawal limit on savings accounts for electronic transfers, automatic transfers (such as overdraft protection) and certain other transfers. However, there is no limitation on transfers or withdrawals made in person or by mail, ATM or phone (via check mailed to the credit union).

With the Federal Reserve Board making changes to the Regulation D requirements, but not specifically the six-transfer limitation, several credit unions have seized the opportunity to voice their support for a revision to the transfer requirements. In this digital age, credit union members are finding this restriction to transfer money online between accounts increasingly burdensome. Not to mention, the compliance challenges for the credit union associated with tracking individual types of withdrawals and placing limitations when necessary are consuming significant resources.

Changes to the Regulation D transfer restrictions have progressed through the years and commenters hope to sway the Board to further relax the six transfer limitation requirement. The League certainly sees value in lifting this restriction for savings account transfers to other accounts at the same institution and will draft its comments to the Board by the December 19, 2011 deadline. If you wish to weigh in, please send an email to regcomments@ncleague.org.

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