Questions and Answers

We are not aware of any Reg. D exemption granted to HSAs. Absent such an exemption, Reg. D applies to deposit account investments under an HSA in the same way it applies to a deposit account outside an HSA. Thus, the savings account transfer limitations, required minimum early withdrawal penalty for time accounts, and reserve requirements for transactions accounts apply to such deposit accounts regardless of whether or not they happen to be part of an investment under an HSA.