Removing Barriers Blog

CUNA Follow Up Letter to the Federal Reserve on Reg D
Posted March 30, 2020 by CUNA Advocacy

CUNA sent a letter to the Federal Reserve today regarding Regulation D Transfer and Withdrawal limits.

In the letter, we state we appreciate that the Fed’s recent FAQs offer a path to eliminate the transfer limit; however, the method detailed of re-designating accounts as transaction accounts and updating reporting to the Federal Reserve is not necessarily a simple one that credit unions can easily make, especially with constrained resources from the Covid-19 pandemic. Therefore, the FAQs do not adequately address our previous request because they maintain the Regulation D in its current form and could lead to inconsistent application by each Reserve Bank. Because credit unions need a less burdensome solution, we, again, are requesting that the Fed remove the transfer and withdrawal limit in § 204.2(d).