John Zasada, Compliance Consulting Director, Financial Institutions Group

On May 13, 2020, the Federal Reserve (Fed) updated the Savings Deposits Frequently Asked Questions (FAQs) in order to account for the Regulation D changes it recently implemented.

The FAQs addressed whether the amendments to Regulation D are temporary or permanent. The Fed stated their current monetary framework is not a short-term decision. They said they do not have plans to re-impose transfer limits but may make adjustments to the definition of savings accounts in response to comments received on their interim final rule and, in the future, if conditions warrant. It also states financial institutions may suspend enforcement of the six-transfer limit, but The Fed does not require financial institutions to do so. The interim final rule does not require financial institutions to change the name of any accounts or products that have the words “savings” or “savings deposit” in the name of the account or product. Finally, the FAQs state the changes to savings accounts in Regulation D do not result in savings accounts being subject to Regulation CC.

If you have questions about these updates, contact Doeren Mayhew’s compliance specialist.