On our FREE Deposit Compliance Q&A Forum presented April 28th, there was some discussion as to whether the recent changes to Regulation D will result in savings accounts being subject to Regulation CC.
For purposes of its funds availability requirements, Regulation CC excludes “savings deposits” from its definition of “account”. Regulation CC points to the Regulation D definition of a savings deposit, which still includes the “reservation of right”, or the ability to require a customer to give written notice of a withdrawal at least seven days in advance.
If you remove the “reservation of right”, the account would no longer be a savings deposit and would be subject to the funds availability requirements of Regulation CC. If you continue to maintain the “reservation of right”, your savings accounts would not be subject to Regulation CC’s funds availability requirements.
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Forum 2020 Follow-up