On 5/13/2020, the Federal Reserve updated their Frequently Asked Questions regarding Regulation D and the recent changes to the rule. Among other things, the updates to the FAQs include the following clarifications:

Question 3 answers the question of whether or not the recent amendments to Regulation D are temporary or permanent. As explained in the answer, the Federal Reserve does not expect the changes to be “short term” and “does not have plans to re-impose transfer limits,” but could if future conditions warrant it.
Question 13 explains what we have been saying the last few weeks: that the recent Reg D changes do not cause savings deposits to be subject to Reg CC hold requirements.

The updated FAQs can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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