Questions and Answers

Under Reg D, if a business customer is writing a check from its savings account to another business to transfer funds, but is coming into the bank to do it, would it count against the number of transfers allowed? 

The scenario you set out sounds somewhat unique to us.  We assume that you are describing a situation where the business is writing a check payable to a third person, but not giving the check to the third person and instead taking it to the bank and asking that the amount be deposited in the third person’s account. 

In this case, the depositor is using a check, so it would count toward the three-checks-per-month limit, even though the depositor is delivering the check to the institution in person. In-person withdrawals do not count toward the six-transfers-per-month nor do in-person transfers from one account of the depositor to another account of the same depositor. But there’s no exemption for checks written to third parties.

(Posted: 08/02/2008)

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The Deposit Accounts Manual can help answer your Reg D account definition and restriction questions.