I was hoping to get some clarification on Regulation D. I understand that customers are limited to 6 "convenience" transfers and withdrawals per month; I need clarification on telephonic transfers. If a customer calls into the bank and physically speaks to an employee to initiate a transfer from a savings account to another account, is that considered a convenience transfer and should that transfer be included towards their limited transactions?
The actual text in the regulation refers to exempt transfers as "such transfers or withdrawals that are made by mail, messenger, automated teller machine, or in person or when such withdrawals are made by telephone (via check mailed to the depositor) regardless of the number of such transfers or withdrawals." 12 CFR §204.2(d)(2). The most conservative interpretation of this suggests that when it comes to the telephone, only withdrawals made in the form of a check mailed to the depositor, and not transfers from one account to another, would be exempt from the six-transfer limit. So erring on the side of caution, any transfers facilitated via telephone that does not involve a check being sent to the borrower should be considered as counting toward the six-transfer limit.
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