The Federal Reserve Board should look at opportunities to increase the Regulation D transfer limit beyond the current six per month, CUNA wrote to the Federal Reserve Monday. The Fed sought comments on an advance notice of proposed rulemaking regarding Regulation D and CUNA used the opportunity to advance its advocacy on increasing the transfer limit.
A section of Regulation D establishes the limit of six transfers per month from a consumer’s savings or money market account when made by various “convenient” methods, such as an electronic or online transfer. After the sixth withdrawal or transfer consumers may only access their funds through an ATM or branch visit.
“We believe such threshold is arbitrary, antiquated, and unnecessary,” the letter reads. “At the very minimum, the Board should increase the transfer limit to at least 25 transactions per month… [W]e believe it is long overdue for the Board to update this limit that has its roots in the early 1980s.”
In addition to the negative affect on consumer access to their funds, CUNA believes the limit can affect a consumer’s overdraft protection, since once the limit is reached overdraft protection cannot be used to transfer funds, leading to denial of debit card transactions unless other forms of overdraft are used to protect an account.