Questions and Answers

Regulation D sets out the definition of a money market deposit account in 12 CFR 204.2(d)(2).  To meet the definition of a money market account, you are right in that you must restrict the number of transfers or withdrawals from the account to no more than six per month and of these six, only three can be by check, draft, debit card or similar order.

Footnote 4 to section 204.2(d)(2) states that for purposes of monitoring the number of transfers or withdrawals by check, draft, etc., institutions have the option of using either the date on the check or the date the item is paid.  What ever method you choose, you must stick to it on a consistent basis.  Mixing and matching to allow the depositor more than 3 withdrawals by check per month would be a violation and the money market account could become reclassified as a demand deposit account.