CUNA strongly supports the Federal Reserve’s decision to remove the limit of account transfers under Regulation D and suggested to the Fed Monday it become permanent. CUNA has pushed for elimination of the limit prior to the onset of the pandemic, and the Fed announced an interim final rule in April removing the limit.

“Eliminating the transfer limits has long been a priority for credit unions. CUNA has a long history of advocating for this change with the Board and Congress and thus credit unions are pleased that the requirement has been eliminated,” the letter reads. “Some have expressed concern that the proposed amendments to Regulation D could be temporary, so we suggest that the final rule make clear that the Board intends to make the changes permanent.”

CUNA also notes initial confusion about how the rule would be impacted by the funds availability requirements under Regulation CC. While this has been cleared up with subsequent guidance, CUNA suggests the Federal Reserve board “review Regulation CC in conjunction with Regulation D to clear up any ambiguous requirements concerning the interplay these regulations.”