Questions and Answers

For purposes of Regulation D and its reserve requirements, transfers accomplished via the internet (personal computer) count towards the six preauthorized, automatic, or telephonic transfers from a savings/money market account allowed per month or per statement cycle. The support for this interpretation comes from language supplementing changes to Reg. D in the March 20, 1986 Federal Register, which indicates that telephonic transfers include not only those accomplished orally by telephone, but also those accomplished by computer, facsimile machine, or other telecommunications access devices. These transfer limitation rules apply to both consumer and commercial account holders.