Academic journal article ABA Banking Journal

Reg D Has Exceptions for Loans, but Not Big Ones

Academic journal article ABA Banking Journal

Reg D Has Exceptions for Loans, but Not Big Ones

Article excerpt

Regulation D does not restrict payments made for loans at the same institution when those payments are made from a money market or savings account (12 C.F.R. 204.2(d)(2)). Does this unlimited transfer ability apply to any loans, or only loans that are in the name of the depositor? For example, would a debit made from a sole-owner money market account to pay a spouse's loan at the same bank count as one of the limited transactions?

Regulation D is not clear on this issue. We contacted the Federal Reserve's legal division for an answer. The response: The loan must be held in the same name as the money market or savings account. The reasoning: If a customer could transfer funds to any loan--even those not in the customer's name--this would create a method of circumventing the transaction limitations by making unlimited payments to third parties. In our example, the transfer would count against the six-per-month transaction limit. (11/6/09)

Grouping fees under Rag DD

The Commentary to Regulation DD, regarding disclosure of fees on periodic statements, reads:

"... the institution must disclose separate totals for the statement period and for the calendar year-to-date. The total dollar amount includes per-item fees as well as interest charges, daily or other periodic fees, or fees charged for maintaining an account in overdraft status, whether the overdraft is by check or by other means. …

Search by... Author
Show... All Results Primary Sources Peer-reviewed

Oops!

An unknown error has occurred. Please click the button below to reload the page. If the problem persists, please try again in a little while.