Academic journal article ABA Banking Journal

The "E-Withdrawal" Enigma

Academic journal article ABA Banking Journal

The "E-Withdrawal" Enigma

Article excerpt

Q. I can't find that Regulation D addresses withdrawal or transfer requests made via e-mail. What if we had a client e-mail us, requesting a withdrawal or transfer, and we created a check, as requested? There is no messenger involved, and the request wasn't made by phone or in person, yet a check would be created. Do you know of any additional guidance or opinion that covers such e-mail requests?

A. We've talked to Federal Reserve Board staffers in the past about e-mails. In short, these regulators believe that Regulation D does cover such transactions. This is because it covers "telephonic (including data transmission) agreement, order, or instruction." E-mail is considered a "data transmission, order, or instruction."

12 CFR 204.2(d)(2) reads:

"(d)((2) The term 'savings deposit' also means: A deposit or account ... from which ... the depositor is permitted or authorized to make no more than six transfers and withdrawals ... to another account (including a transaction account) of the depositor at the same institution or to a third party by means of a preauthorized or automatic transfer, or telephonic (including data transmission) agreement, order or instruction, and no more than three of the six such transfers may be made by check, draft, debit card, or similar order made by the depositor and payable to third parties. …

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