A Note from CU*Answers: Responding to FRB Changes to Reg. D

In response to the Federal Reserve publication released on Friday, April 24, 2020, the following explains how your credit union can modify your existing Reg D configurations in CU*BASE to temporarily suspend the maximum # of transfers restriction.

If you simply wish to stop warning members directly, the Reg D warning message for online/mobile banking can be temporarily disabled via Tool #751 Reg D/Trans Handling & Analysis Rules (select Maintain Reg. D Transaction Policy).  Keep in mind that the Phone Operator message cannot be disabled, so your employees will still see this warning.  Make sure that your call center operators know how they should respond.  The system will continue to track activity as usual and generate your daily violators report.

If you wish to stop tracking Reg D transfers entirely and no longer see the messages in Phone Operator, you can uncheck the Reg D transaction account flag for all appropriate dividend applications via Tool #777 Savings/Checking Products Config.  This will leave your Reg D transaction settings in place so that you can reactivate the flag on all DivApls later when the order is restored.  You will, however, no longer receive the daily violators report to track transfers on these accounts.

If you charge a fee for Reg D violations, this can be disabled via Tool #810 Service Charge Configuration (select Transaction service charge).  You don’t need to delete the existing service charge program, however.  Instead, uncheck the Activate this service charge program checkbox under Program Settings and Criteria.  Keep in mind that if your fee is charged monthly and you make this change before the end of April, then your fees for any Reg D violations in April will not be charged.

If you have any questions or require assistance, please reach out to our Client Services & Education Team.