This section highlights examiner insights and sound practices gained from examinations of community banks within the Fifth Federal Reserve District.
Consumer Affairs: Savings Accounts
Section 204.2(d)(2) of Regulation D provides that for a “savings account” — which includes a money market deposit account (MMDA) — preauthorized withdrawals are limited to six per calendar month or statement cycle (of at least four weeks). Institutions must either prevent excess withdrawals or implement a process that monitors such withdrawals and notifies depositors that exceed the limit. The account must be closed or reclassified as a transaction account if the account holder exceeds the withdrawal limitation more than occasionally. Examiners have recently cited violations involving both the absence of an established monitoring process and the failure of established processes. Causes of violations have included failure to ensure that all MMDA and savings accounts are included in the monitoring process, inadequate training, and lack of controls to ensure closure or reclassification of accounts when required. Even in a rapidly changing regulatory environment, banks should not lose focus of controls designed to ensure compliance with well-established rules.
If you have any questions about any of these or other topics, please contact your Fifth District relationship manager or email BKSRCommunications.RICH@rich.frb.org.
The analyses and conclusions set forth in this publication are those of the authors and do not necessarily indicate concurrence by the Board of Governors, the Federal Reserve Banks, or the members of their staffs. Although we strive to make the information in this publication as accurate as possible, it is made available for educational and informational purposes only. Accordingly, for purposes of determining compliance with any legal requirement, the statements and views expressed in this publication do not constitute an interpretation of any law, rule or regulation by the Board or by the officials or employees of the Federal Reserve System.
Supervision, Regulation & Credit