It’s not that simple. The Reg D changes include more than just removing the monthly limit on convenient transfers. Accountholders need to be notified;agreements and disclosures need to be reviewed; and brochures, websites,and social media must be checked – all to ensure that language about transaction limitations is not inaccurate or misleading.
- Understand the Federal Reserve’s rationale for amending Regulation D
- Analyze the impact of the changes on your institution
- Implement the action items to ensure compliance
- Confidently review and amend agreements and notices
- Explain the importance of timely action to avoid UDAAP and compliance risks
On April 24, 2020, the Federal Reserve adopted an interim final rule under Regulation D,which removed the six-per-month limit on convenient transfers from savings and money market accounts. These changes presented a number of short- and long-term changes for depository institutions. In the short term, depository institutions were permitted (but not required) to immediately suspend enforcement of the convenient transfer limitation. Now,depository institutions need to review their agreements, disclosures, and other information (e.g., brochures, websites, etc.) to ensure that the language regarding transaction limitations is not inaccurate or misleading – and ensure that accountholders have been appropriately notified of the changes.
This webinar will cut through the confusion by summarizing the Reg D changes, explaining the impact, and providing a clear, detailed compliance game plan. Attendees will receive a detailed summary and a list of action items explaining which areas need to be reviewed and revised to align with the changes. In addition, it will address the possibility of retaining transaction limitations on savings and money market accounts and how to update agreements and disclosures. Frequently asked questions will also be reviewed and answered.