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Updated on Thursday, April 30, 2020
If you have a savings or money market account, you may have noticed that there’s a rule that goes with it — no more than six transfers or withdrawals per month from the account. It may feel oddly specific, but it’s true for all savings accounts at all banks and credit unions. Congratulations, you’ve experienced Regulation D.
Note: Due to the coronavirus pandemic and its widespread implications, the Federal Reserve has temporarily amended Regulation D to delete the six-transaction-limit on “convenient” transfers. This amendment allows institutions to immediately suspend enforcement of this rule and allows consumers to immediately take advantage of this waiver.
This opens up the opportunity for folks to avoid further penalties when they need to access funds from a savings account during this time. This suspension applies to all savings accounts across financial institutions, many of which are also temporarily waiving excessive transaction fees anyways. Check whether your bank offers COVID-19 relief here.
What is Regulation D?
Regulation D refers to the Federal Reserve’s reserve requirements for depository institutions — or, more plainly, how much money a bank needs to hold in reserve as a percentage of the total amount of money it owes to its customers. So, for instance, currently banks must keep a minimum reserve of 3% of the total amount over $16.3 million and 10% of the total amount over $124.2 million.
Why is this important? “It’s designed to make sure that banks have an appropriate amount of money in reserve,” says Robert Föehl, J.D., executive-in-residence for business law and ethics at Ohio University’s College of Business. “It’s about making sure that banks are safe and sound.”
As part of these reserve requirements, banks must classify what types of deposit accounts they have and keep reserves accordingly. For accounts categorized as savings accounts, Regulation D limits bank customers to six transfers or withdrawals per month. This rule is in place, in part, because banks aren’t required to hold a reserve against savings accounts.
In general, transaction accounts, which include checking accounts, are considered riskier types of deposits. “You write a check; that check could bounce,” Föehl says. “There’s more risk to the financial institution to have transaction accounts than to have savings accounts.”
Savings accounts are considered safer for banks because — by definition — people aren’t using them for all of their financial business. If you’re writing all your checks on your savings account, it’s not really a savings account. “You can’t call something a savings account if it’s a transaction account,” Föehl says. “This is where the limit comes into play.”
Regulation D’s limits are also a way of encouraging people to save, says Mayra Rodríguez Valladares, a financial regulation consultant and trainer in New York City. “The downside is that if you wanted to withdraw more than six transactions a month you could incur some kind of penalty,” she says.
How does Regulation D work for customers?
If you go over your allowed six transfers or withdrawals, your bank may charge you a fee. If you do it regularly, they may convert your account to a checking account or even close your account entirely.
In general, any account that limits “convenient” transfers and withdrawals is considered a savings deposit account and would be covered by Regulation D. These include:
- Savings accounts: Deposit accounts in which a customer earns interest on the money they deposit, which often have lower minimum deposits.
- Money market accounts: Deposit accounts in which a customer earns interest on the money they deposit, and the interest is typically higher than a savings account.
These accounts also come with a “reservation of right” requirement, in which the bank reserves the right, at any time, to require seven days’ written notice of an intended withdrawal — but banks don’t typically do this in practice.
Transactions that are limited under Regulation D
Essentially, Regulation D caps transactions that are considered easy for you to initiate without having to drive to a bank or visit an ATM. That would include:
- Preauthorized, automatic transactions — including those from a savings account for overdraft protection or for direct bill payments
- Telephone transfers
- Withdrawals initiated by fax, computer, email or the internet
- Transfers made by check, debit card or another similar method made by the depositor and payable to third parties
How can I get around the limits of Regulation D?
You may bypass the six-withdrawal limit under certain conditions, including if you’re willing to travel to your local branch in person. “It’s getting to be less and less of a problem,” Valladares says. Transactions that don’t go against your limit include:
- Transfers and withdrawals made in person at the bank
- Withdrawals and transfers requested by mail
- ATM withdrawals and transfers
- Transfers and withdrawals initiated by telephone, where the withdrawal gets disbursed as a check and mailed to the depositor
How to avoid trouble with Regulation D
If you’re feeling hemmed in by the six-transaction limit of your savings accounts, there are a few ways to work around it:
- Visit your bank branch or ATM. Transactions made at your local branch or from your bank’s ATM don’t go against your monthly limit — this is the simplest way to avoid trouble with Regulation D.
- Plan ahead. If you know you’ll need a certain amount of money in a month, don’t drag it out over multiple transactions — get what you need in fewer trips. Withdraw more at a time.
- Decline overdraft protection. Generally, overdraft protection works by dipping into your savings account if you write a check that your checking account can’t cover. That counts as one of your six transactions, but if you decline overdraft protection, it can’t happen.
- Get a checking account. If you need more than six transfers or withdrawals, save yourself some trouble and get a checking account with unlimited transaction power.
- Don’t pay bills from your savings or money market accounts. Your checking account makes the most sense for regular payment withdrawals. Reconsider setting up a direct debit from your savings account, which will count toward your six transactions.