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Short Survey on Reg D transaction limitation of 6 Implementation

  • 1.  Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 22 days ago

     

     

    1.      When do you plan to remove the Reg D convenience transaction limitation of 6 from your non-transaction accounts?

    2.     Do you plan to impose any limitations on any convenience transfers? If so, what will they be: How many and what methods will be limited (overdraft transfers, online transfers, etc...)

    3.     Do you plan to charge for any convenience transfers, i.e. overdraft transfers? If so, are you giving any free?

    4.    If you are not imposing limitations or charging, do you plan on removing the limit before you update disclosures such as Truth-In-Savings and Membership and Account Agreement?

     

     

    David W Proffitt

     

    President and CEO

    Alcoa Tenn Federal Credit Union

    865-380-6262

     





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  • 2.  RE: Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 21 days ago
    David:

    1. The limit of 6 was immediately removed after the official announcement by the Federal Reserve Board - same day!  Also completed immediately, were "good news" communications sent to all members.

    2. No, none. It's the members' money and people don't need us to "force" them to save. By the way, the savings rate now is at its highest level since 1981 (roughly 40 years ago). COVID-19 crisis or not, people will still utilize savings accounts. Financial Institutions should not retain any savings account restrictions, particularly on the younger members who wouldn't ever think of visiting a branch or even an ATM for cash (check the ATM transaction levels, as they are dropping with branch transactions). This is as much about "getting up with the times" on banking patterns and helping low-to-moderate members and COVID-19 access to cash, as it is about savings accounts. The 100+ year regulation should have been repealed decades ago. If you keep your restrictions, competitors are going to each your lunch. Good luck if you choose that path.

    3. Nope.

    4. Yes...gone already.

    P.S. Having grown up in NH, I love the Moose pic

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    Bernard McLaughlin
    President/CEO
    Point Breeze CU
    Hunt Valley MD
    410.771.3850
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  • 3.  RE: Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 21 days ago
    1. Removed it the day it was announced
    2. No
    3. No
    4. Changed them already without updating disclosures.  The change is in the benefit to the member and therefore little risk. 

     

    Matthew P. Piazza, CPA

    PRESIDENT & CEO

    O: 410.584.7474 ext.240

    F:  410.584.8061

    mpiazza@affcu.org

    www.affcu.org

     

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  • 4.  RE: Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 21 days ago
    1. Removed same day.
    2. No
    3. No
    4. Have not updated disclosures yet.

     

    Jason Garner

     






  • 5.  RE: Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 21 days ago

       

    Good Morning,

    1. We changed it the day of the Fed Announcement
    2. No
    3. No
    4. We have not updated disclosures as it is a benefit to our members and plan to revert back after the limit is reinstated

    Have a wonderful day and stay healthy!

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    Danielle Green
    Director of Branches
    Credit Union West
    Glendale AZ
    602.631.3405
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  • 6.  RE: Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 21 days ago
    ​Thank for you, we plan to follow suite!

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    David Proffitt
    President/CEO
    Alcoa Tenn FCU
    Alcoa TN
    865.380.6262
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  • 7.  RE: Short Survey on Reg D transaction limitation of 6 Implementation

    Posted 21 days ago
    1. Salal removed the $25 Reg. D fee (called "Excessive Transaction Fee") on May 1
    2. No.
    3. Salal had (and will maintain) an "Overdraft Transfer Fee" of $5 - defined as a transfer from a Salal Credit Union checking, savings, or line of credit (fees for overdraft transfers from your line of credit are disclosed in the applicable credit agreement) to cover payment of an item or items in a checking account with an insufficient balance.
    4. After consulting compliance and council, Salal determined we would disclose this as "temporary" on April's statements, with the idea - should it remain in place, the Membership Account Agreement will be changed in a forthcoming update.

    Below is our internal communication relating to this change:

    Summary

    Last Friday, the Federal Reserve Board made changes to Regulation D (Reserve Requirements of Depository Institutions) allowing financial institutions to temporarily not enforce the six (6) transfer limitation on savings accounts.

     

    In other words, effective tomorrow (May 1st), members with savings accounts at Salal will have the ability to make unlimited pre-authorized transfers from savings accounts, including ACH and transfers to checking accounts.

     

    Here's What You Need to Know

    • We will no longer assess the Excessive Transaction Fee, are turning off automatic generation of the Excessive Transactions letter and account conversions (for those who exceeded the old limit).
    • Online Banking will be updated on Monday, May 4 to accommodate these changes.
    • Episys will be updated to no longer track these transactions.
    • The following notice will be added to our April statements:

    "Notice to Members: As of May 1, 2020, Salal Credit Union is temporarily exercising its option to not enforce savings account transfer limitations as disclosed in your Membership Account Agreement; the number of pre-authorized transfers, telephone transfers, online banking transfers, or checks (Money Market Accounts only) was previously six per month. Salal Credit Union members can now enjoy an unlimited number of transactions from savings accounts without incurring an Excessive Transfer fee."

     



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    Skott Pope CCE
    SVP/Retail Financial Services
    Salal CU
    Seattle WA
    206.826.7626
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