NCUA has issued guidance to credit unions on issues related the Federal Reserve’s changes to transfer limits under Regulation D. The Federal Reserve has issued an Interim Final Rule (IFR) amending Regulation D by removing the 6/month limit on transfers from savings deposits. Credit unions may now suspend enforcement of the limit immediately and permit members to make unlimited withdrawals and transfers from their savings deposits. The IFR became effective on April 24, 2020. The Federal Reserve also published FAQs that will be updated as needed.
In addition to the changes made by the IFR, the Federal Reserve had issued an earlier interim rule reducing reserve requirement ratios to 0% effective March 26, 2020.
It is up to the credit union whether to waive the transaction limit as now permitted by the IFR: it is not mandatory. Credit unions may also use their discretion to decide how they want to classify savings accounts IF they choose to waive the limit: credit unions MAY reclassify them as transaction accounts OR continue to classify them as non-transaction accounts even with the limits waived.
Credit unions should be aware of the impact of this interim final rule on account agreements and related matters.