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The Fed Amends Reg D to Remove 6-Per-Month Limit on Savings Accounts

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The Federal Reserve Board announced today that it has amended Regulation D (Reg D) to permit banks and credit unions to allow their customers to make more than six payments or withdrawals per month from their savings and money market accounts. This was done in part to give customers easier access to their funds during the COVID-19 pandemic. It is one of the many actions the Fed has taken in the last two months to combat the economic effects of the pandemic.

The first thing to note about this Reg D change is that it does not require institutions to suspend their excessive transaction policies. It’s up to the bank or credit union. Some bank policies include fees when customers exceed six payments or withdrawals per month. Some banks also have policies that give them the right to close savings accounts if customers regularly exceed this limit. Before you choose to exceed this limit, make sure to check with your bank or credit union. If they haven’t suspended enforcement of this limit, be sure to let them know that they can no longer blame federal regulations on their policy.

Another thing to note is that this rule change may just be temporary. I am still trying to get clarification. The Fed’s press release and FAQs are not clear on this question. At first I thought that “interim final rule” in the press release title implied a temporary change, but after researching the definition of this, that does not seem to be the case. One would think that the Fed’s FAQs would specifically address this question, but it does not. Also, the press release and the FAQs state in several instances that institutions may “suspend enforcement of the six transfer limit.” The definition of “suspend” implies a temporary condition. However, if this rule change is temporary, one would think that the Fed would include an end date. If this rule change is temporary, it seems likely that it should last through 2020 at the very least. I’ll update this post once I receive clarification.

Update 7/27/20: The Fed has updated its FAQs with an answer to the question about if this rule change is temporary or permanent. The answer suggests it's permanent, but there is a possibility of changes based on feedback and future conditions. Below is an excerpt to the Fed's answer:

The Committee’s choice of a monetary policy framework is not a short-term choice. The Board does not have plans to re-impose transfer limits but may make adjustments to the definition of savings accounts in response to comments received on the Board’s interim final rule and, in the future, if conditions warrant.

Below is a copy of the press release from the Federal Reserve Board so you can interpret it for yourself.

Federal Reserve Board announces interim final rule to delete the six-per-month limit on convenient transfers from the "savings deposit" definition in Regulation D

The Federal Reserve Board on Friday announced an interim final rule to amend Regulation D (Reserve Requirements of Depository Institutions) to delete the six-per-month limit on convenient transfers from the "savings deposit" definition. The interim final rule allows depository institutions immediately to suspend enforcement of the six transfer limit and to allow their customers to make an unlimited number of convenient transfers and withdrawals from their savings deposits at a time when financial events associated with the coronavirus pandemic have made such access more urgent.

The regulatory limit in Regulation D was the basis for distinguishing between reservable "transaction accounts" and non-reservable "savings deposits." The Board's recent action reducing all reserve requirement ratios to zero has rendered this regulatory distinction unnecessary.

Concurrently, the Federal Reserve is making temporary revisions to the FR 2900 series, FR Y-9, and FR 2886b reports to reflect the amendments to Regulation D.

The Fed’s FAQs page is available here.

In addition to making it easier for depositors to access their funds during the COVID-19 pandemic, the Fed provided another reason for this change. In March the Fed eliminated reserve requirements on all transaction accounts. This was another way for the Fed to support more lending by banks and credit unions. The elimination of the reserve requirement made the transaction limit distinction between checking accounts and savings accounts unnecessary.

For details on the old transaction limits of Regulation D, please refer to this DA article on Regulation D and how it affects depositors. The last change in transaction limits of Regulation D was after the 2008 Financial Crisis. In May 2009, the Fed announced changes to Regulation D to permit institutions to allow customers to write up to six checks per month from money market accounts instead of just three. Previous to this change, withdrawals or payments by check were treated differently than electronic withdrawals or payments.

Ways This Reg D Change Will Impact Savers

Depositors must first wait on their banks and credit unions to remove the six-per-month limit on their savings and money market accounts before depositors can benefit from this Reg D change.

Once the bank or credit union makes the changes, it may allow savers to earn more interest. Currently, depositors have to maintain adequate checking account balances to cover all of their regular payments. To avoid overdrafts, many depositors keep a sizable balance in their checking accounts. Free overdraft transfer policies (like those from Ally Bank) has made it easier to maintain a smaller checking account balance, but depositors still had to avoid excessive overdrafts since they count toward the excessive transaction limit. If banks and credit unions now eliminate the excessive transaction limit, savers can use their money market or savings accounts to make regular payments without worrying about the number of transactions. Also, if the institution offers free overdraft transfers, depositors can maintain only a small amount in their checking accounts. This will allow the vast majority of their funds to reside in the savings or money market accounts which typically earn much higher interest rates than the checking account.

A possible negative impact from this Reg D change is that it could put more downward pressure on savings account rates, especially at online banks that offer both low-interest checking accounts and high-interest savings accounts. This assumes that many depositors will react to this policy change and reduce their balances they maintain in their low-interest checking accounts and increase their balances in their high-interest savings accounts.

Waiting on the Banks and Credit Unions

The higher interest cost to banks may be a reason that banks won’t be in a rush to change their excessive transaction policies. It will be interesting to see how fast banks and credit unions react. Ally Bank already has suspended their excessive transaction fees due to the COVID-19 pandemic. However, as I described in my review of Ally’s COVID-19 relief package, Ally was still discouraging customers from making unlimited withdrawals from their savings and money market accounts. I’ve asked Ally if they plan to make changes based on today’s Reg D change. I’ll be sure to provide an update once I hear from them. If your bank or credit union announces a policy change, please let us know in the comments.

Comments
jimdog
  |     |   Comment #1
This will not help very many! The FED needs to stop promoting debt and speculation with near-zero interest rates for one.
midas89
  |     |   Comment #2
A sincere thank you, Ken, for this detailed information on the Fed's Regulation D suspension. And thank you for updating us if you eventually find out if the Fed means this to just be temporary (which would be my initial guess).
deplorable 1
  |     |   Comment #3
Finally! I have been hoping that this policy would be changed permanently. At the very least they need to increase the number of withdrawals allowed per month. This is one of the major reasons I have so many accounts to get around the "regulation D" requirements. I just ran into this cap last week trying to move money around and got the fee reversed. Thanks for posting this Ken.
me1004
  |     |   Comment #8
Yes, I do too. I have three savings account at my hub credit union, so I can pay my bills via direct ACH from the higher interest savings.

I find it outrageous that even checking accounts are not getting good rates, the bank is making plenty of money on loans off of them, you should get a fair share, not nothing or little.

But I do think the Fed should bar banks or credit unions from imposing fees for more withdrawals. The confusion such bank rules would create would be a horror. (BTW, the rule applies only to withdrawals, not to deposits. I prefer to say "withdrawals" to be clear, rather than"transactions from.")
SalmoTrutta
  |     |   Comment #63
The FDIC should reduce deposit insurance levels to c. $10,000 per tax id. The present limit of $250,000 keeps too much idled money in the payment's system. From the standpoint of the system, the economy, banks pay for their earning asset with new money -- not existing deposits. All bank held savings are un-used and un-spent, lost to both consumption and investment. This is the sole cause of Alvin Hansen's "secular stagnation" (chronically deficient AD).

This is the sole reason why nominal rates, and the real rate of interest, have declined since 1981. Bank held savings destroy money velocity period.
Science and Facts not Lies
  |     |   Comment #4
Glad to see at least a temporary rollback of the Reg D "6 max" limit -- though as your post says, in the end it's really up the the individual FIs (Alliant allows only 6 no matter what... others will allow more for a fee... and one CU by me doesn't seem to care at all). But I just don't know if it will ever trickle down to consumers, though. The FIs that charge fees for going over 6 aren't going to want to lose a revenue source. And for the others... this probably isn't high priority. Definitely good to see, but wonder if we'll actually SEE any change ourselves...
Predatory Depositor
  |     |   Comment #5
Well I guess I've become the resident curmudgeon and it falls on me to have to give the dismal view. I'm not so sure I would cheer the end of Reg D. I think Regulation D is one reason why savings accounts have higher interest rates than checking accounts. It makes them more profitable to the banks because people will tend to keep higher more stable balances if the number of withdrawals are limited. Part of that extra profit is passed along to the depositor.

So I think it's possible that the the absence of Regulation D might result in lower rates on savings accounts than they otherwise might have had. And I know how popular lower rates are on this site. About as popular as a bucket full of covid-19 in the living room.
Predatory Depositor
  |     |   Comment #6
Whewww I'm relieved. I see Ken already addressed this issue it is article. I don't have to be the cynical bad guy this time. Probably should have read it first ;-)
Bozo
  |     |   Comment #7
PredDep, well , I must agree with your comment. It's the law of unintended consequences. In the guise of "helping" depositors, the FED may have given the green light for FIs to lower rates on garden-variety savings accounts, as savings accounts morph into demand deposits. I'm going to be watching what happens to my Alliant savings account (currently at 1.35% APY) at the end of this month. I was planning to let my one-year CD (maturing in September) roll into my savings account, but that may change.
SalmoTrutta
  |     |   Comment #64
The complete deregulation of interest rates for the commercial banks was a gargantuan mistake. The nonbanks do not compete with the banks. The nonbanks are the bank’s customers. It is non-bank deposits that should be government insured as they expeditiously activate savings.
deplorable 1
  |     |   Comment #10
I see your point PD but with FED rates at 0% already I can't see savings account interest rates staying very high no matter what anyway. For me it's all about convenience and ease of use which is why I already use corporate debt accounts currently to pay bills since I get a savings account yield with no 6 withdrawal limit or fees. Since this isn't FDIC insured I don't keep a high balance there so I need several savings accounts as well.
I also do several transactions per month(probably more than most) many automatic to keep certain high yield accounts fee free. I have to be able to move cash around quickly to take advantage of time limited bank bonuses, CD's, investment opportunities, paying off 0% bt offers at then end of the term etc. on top of all those automatic transactions. I keep almost nothing in a checking account earning 0% it's just a local place for direct deposit, ATM withdrawals, check cashing etc.
If banks and credit unions stop charging fees for withdrawals over 6/mo. It would simplify my finances greatly
Predatory Depositor
  |     |   Comment #12
I hear ya dp1. I have several accounts that I have my automatic bill pays come from and other accounts for taxes. It's a pain. But in some ways this is the worst time for savings account rates to fall for me because I have a large amount of IRA funds maturing and need to temporarily store them in a savings account until I figure out what I'm going to do with them. I had just made the arrangements and decisions about it. The more savings account rates drop now, the sadder the plan gets. We'll see what happens. I think everything is in flux. I am far more concerned about opening up the economy than I am about rates. Rates won't mean a thing if the banking system collapses. And if we don't get the economy open... at some point it will. We MUST get people back to work and stop spending money the government doesn't have!
Predatory Depositor
  |     |   Comment #14
By the way, I'm not going to change anything about my savings accounts since right now it seems this may only be temporary. Unless it's permanent, it's not worth the work.
deplorable 1
  |     |   Comment #22
Same here PD no point in making any permanent changes until we see how this all shakes out. Competition in the banking industry should keep competitive savings rates alive I would think.
I was wondering if the FED was going to make such a move since in person banking has been somewhat restricted.
My local BoA checking had closed their drive-thru prior to the covid-19 outbreak. I bet they regret that decision now. Not sure what I'm supposed to to when I get a large check to deposit from a maturing CD or 0% balance transfer. It seems you have to now make an appointment in Michigan to do any banking. Luckily I can do 99% of my banking online with so many accounts.
Maybe the FED needs to boost the limit for mobile banking app deposits as well. If they don't want you to go into the bank this seems like a logical solution. The limits were always too low anyway IMO.
milty
  |     |   Comment #24
@PD#12: My, my . . . I am totally befuddled why you would do anything will all your huge savings funds except flood them into the stock market, after all that is what the Fed wants you to do and you know you can't fight the Fed.

But seriously, I use one FI to pay bills and numerous others for investment, and have never really had a problem with Reg D (or following FDIC/NCUA limits), but of course one needs to be aware of these limits as well as each FI's own limits and plan accordingly.
deplorable 1
  |     |   Comment #32
@Milty: I agree on the planning ahead part but one of the reasons I keep running into the 6 withdrawal per month limit is the trial deposit verification method for linking accounts. Where they do 2 small deposits and 2 small withdrawals of less than $1. Many banks and credit unions were counting those 2 small withdrawals against your 6 for the month and if you needed to link multiple accounts well there goes all your withdrawals for that month. One FI actually threatened to close my account and I only did 3 withdrawals that month the other 4 were trial deposit withdrawals. You can see how this can get frustrating very quickly particularly while setting up a newly opened account.
Milty
  |     |   Comment #41
@D1: Good point. I certainly can understand how that 6 transfer limit could be an issue when linking accounts. I guess I never ran into it since I use a Hub account to link most of the banks (use shared branching for CUs, which works best for me), where these links were established over a lengthy enough time period that it never hit that threshold. And of course have been vigilant about removing poor performing accounts, which unfortunately as of late has certainly reduced the number of FIs I do business with.
InterestYields
  |     |   Comment #9
Thanks Ken, beyond reporting what you hear back from Ally Bank (ordinarily charged $10 per transaction in excess of the monthly 6), could you also ask Marcus Bank which does not charge such fees?
  
According to Marcus Bank it simply wouldn't allow more than 6 monthly transactions per Savings account, requiring the opening of multiple Savings accounts if more transactions are needed, particularly as they still don't offer checking accounts.  Marcus may be in a good position to change this limitation, their online banking is newer and under constant development.  Unfortunately Marcus Bank servers are still not as stable as Ally Bank in my experience and they really should consolidate all accounts on one monthly statement rather than separate PDF statements for each account (hopefully their 1099-INT for 2020 will include a Total 1099-INT line unlike in 2019).  Marcus should also join every other online bank with a secure message center and not just rely on the hassles of call centers and their unreliable chat.  With their recent rate drops Marcus Bank is becoming less interesting but I do like that interest is earned the same business day if transfers are scheduled before 6 PM and no wire fees.
51hh
  |     |   Comment #11
I would be interested in how BofA and Alliant react to this change.
deskandchairs
  |     |   Comment #16
InterestYields...perhaps you could copy your comments about Marcus and post them as a review for Marcus. Potential depositors (who are users of this site) would benefit from knowing these wrinkles before opening an account. Your comments are basically lost here...
Lisa
  |     |   Comment #17
It will help many who cannot go into the branch to conduct business now. Banks and credit unions are closed, and open only by appointment only. The reg allows only 6 per month via online and via phone, then in person as many as you want....resets the next month...so for the fact that in person isnt a viable option.....this is a very good thing.....keep people home
Joe
  |     |   Comment #18
This change will be total destruction on the savings and MM accounts. Now the banks and CUs will convert them into semi checking accounts and no interest will be paid. The FIs need to make a buck and a buck there to stay in business, have you ever thought of that?
Choice
  |     |   Comment #19
By being able to loan what use to be reserves FIs will make substantially more...Watson
Jennifer
  |     |   Comment #21
I can't decide if this is good or bad news. I do simply adore the idea of not having to worry about a limit of six per month.
Predatory Depositor
  |     |   Comment #23
As with most things the government does, it has both good and bad aspects to it. What the net result is... No one knows.

I think it's safe to say though, that the potential damage that will be done to the economy by suspending this law is trivial compared to the massive debt the government is incurring piled on top of the massive debt they've already piled up.

The apparent implication of all this out of control government spending is that the prospect of inflation looms large. But we cannot afford increases in rates because the monumental debt service on the national debt is already teetering on the brink of catastrophy.

I think those who count on the welfare of their bank deposits should be less concerned with the number of withdrawals they can make from their accounts and more focused on contacting their governors, senators and congressmen to demand that they get businesses open and employee's back to work as soon as possible. If that doesn't happen, and soon, there won't be any banks.
Marr
  |     |   Comment #38
There is cost involved to each bank transaction, if there is no limit, be your own judge of what will happen to those accounts.
me1004
  |     |   Comment #50
Years ago, there were never any transaction limits on savings accounts. And they paid interest rates that got them the same spread compared to loan rates as we get on savings accounts now. So, they might exploit this new rule, but it is not economic forces pushing them to, it is simply because they can.
Sandra
  |     |   Comment #29
I hope this will have the effect of raising the monthly dollar limit on withdrawals. For example, Alliant CU currently has a $25K limit per withdrawal which effectively limits your monthly withdrawal to 6 X 25K = 150K. I realize it is still up to the bank/CU to decide what its new limits will be, but I hope this will encourage them to loosen up a little.
111
  |     |   Comment #31
I have Alliant accounts also, and I'm afraid that the "25K limit" you refer to is actually a 25K ACH withdrawal limit PER DAY, not per ACH withdrawal. At least, that's the case for me. A few years ago they had a higher limit.
Marr
  |     |   Comment #39
The banks and CUs can make our life more miserable if they lower the transfer limits to $1K per day and only one transaction per day. That is not in the regulation "D", something to think about it.
Predatory Depositor
  |     |   Comment #40
I think how this pans out for depositors is going to depend on whether it's temporary or permanent.

If this is a temporary change, say for just a couple of months, I don't think it will have much of an effect.

But if this is a permanent change, it essentially means they are eliminating the distinction between checking accounts and savings accounts, and the two will probably be combined into one kind of account. I don't think that would be good news for most depositors because it would almost certainly mean that you will earn a lower return on your liquid funds. The only people who would benefit would be people who keep a low balance in their liquid funds and make money withdrawals.

Think of it this way. Banks have been in favor of eliminating Reg D for a long time. Why do you think that is? Could it be because it would lead to paying lower rates on their liquid deposits and put an end the rate competition on savings accounts? Nahhhhhhhhhh
Predatory Depositor
  |     |   Comment #42
The elimination of Reg D might benefit borrowers though. If banks pay lower rates on their deposits it theoretically means they can offer more competitive rates on loans.

It's really difficult to predict what these things will lead to in the banking industry because the industry is so highly regulated that conventional analysis of supply and demand and other normal market forces is thwarted by conflicting regulations. I suspect the fact that the banking industry favors elimination of Reg D means they have modeled it out and concluded that it benefits them and not necessarily their customers. So I think there is reason for depositors to be skeptical of this change.
deskandchairs
  |     |   Comment #48
Banks are like every other business in that they want to be able to compete with as few restrictions as possible. I think you will see this demonstrated (unless this change is really temp). Some depository institutions will still charge a fee after 3 (not 6) transfers while others will remove limits, as they seek to attract depositors. This is the freedom to pursue different strategies. However, I think they will find customers. like most depositors on this board, are moved by yield, regardless of administrative restrictions, but they will spend most of their time whining about the restrictions, while depending on Ken to identify the best yields and go there.
wtpo3
  |     |   Comment #53
I wrote to the lead customer care banker at Western State Bank and received this response: Our Compliance team has responded stating Regulation D transaction limits are no longer required. As a result Western State Bank will not be enforcing these limits going forward. This however is only going to be eliminating the counting and limiting of convenient transfers on these accounts, not the online banking transfer limits currently in place.
Vancouver
  |     |   Comment #54
Well, I work the daily Reg D report and I can't wait to hear and see what my Community Bank does, I'm so over this report, it's an outdated old law. :-)
wtpo3
  |     |   Comment #55
I wrote a message to Alliant Credit Union asking about Regulation D. This is the response that I received:

Thank you for your email. We will be taking off the restriction but we do not have an eta on when this will be done. If you meet your max of 6 per month please send us a message and we will reset the number of transfers.
wtpo3
  |     |   Comment #56
This is the response I received from HSBC Bank USA regarding HSBC Direct Savings:

Great News! HSBC has announced their decision to remove the rule that limits consumers to six transactions each month from their savings accounts.

You now have more convenient access to your funds and to have the flexibility to freely transfer funds between your accounts for everyday expenses and/or to manage your personal finances.

There has not been an end date set for the limit to be reinstated.
NRkey
  |     |   Comment #57
From Signal Financial:

“ Dear Member,

Due to the current COVID-19 pandemic, the Federal Reserve made the decision to temporarily suspend the monthly six-transfer limit imposed on savings, club, and money market share accounts. Signal Financial FCU implemented this temporary change effective April 30, 2020. Should the Federal Reserve decide to end the temporary measure, we will advise you of the change in advance. ”
John
  |     |   Comment #58
Are banks expected to stop counting or are they expected to continue counting and limit to 6? Whenever this rule goes away, since it is an adverse impact, all the banks that implement this would need to communicate 'Change in Terms' ?
Chan8alex28
  |     |   Comment #59
Thank you. I used the article to inform myself before calling my bank today. The audience also needs to know that as of today, some banks, Citizens bank, have interpreted this suspension as optional and will continue to impose fees due to "the Fed is going to put this back in place real soon" I was told by a supervisor. However, you can call and request a rebate once the fees are taken out. I am posting this so that we all do the research on the loop holes so disappointed expected. Not a requirement but a suggestion.
Choice
  |     |   Comment #60
Chan, your post reminds me...if one has not sought a refund or suspension of Medicare or ...premiums for so-called Advantage programs b/c contracted services are NOT being provided one may want to do so ... While clearly an Ethics 101 challenge by those providers, if not illegal, they are not doing it for all! Shame on them and government regulators
SalmoTrutta
  |     |   Comment #61
Banks pay for deposits that they collectively, as a system, already own. The source of interest bearing deposits is non interest bearing deposits directly or indirectly via the currency route (never more than a short-term seasonal variation), or through the bank's undivided profits accounts.

There is a one-to-one relationship between time and demand deposits. An increase in TDs depletes DDs by an equivalent amount. And the source of bank deposits (loans=deposits, not the other way around), can be largely accounted for by the expansion of Reserve bank credit.

That there is a close connection between aggregate bank credit and the aggregate volume of bank deposits can be verified by comparing the net changes in commercial bank credit to the net changes in total deposits for any given time period.

In other words, the commercial banks cannot expand their earning assets by attracting something (derivative deposits) that they collectively already own. Since time deposits originate within the banking system, there cannot be an “inflow” of time deposits and the growth of time deposits cannot, per se, increase the size of the banking system. But because of the economies of scale, the largest banks can outbid / redistribute the smaller banks’ deposits.
SalmoTrutta
  |     |   Comment #62
Alan Greenspan reduced reserve requirements by 40 percent. That caused the GFC. By mid-1995 (a deliberate and misguided policy change by Alan Greenspan in order to jump start the economy after the July 1990 –Mar 1991 recession), legal, fractional, reserves (not prudential), ceased to be binding – as increasing levels of vault cash/larger ATM networks, retail deposit sweep programs (c. 1994), fewer applicable deposit classifications (including allocating "low-reserve tranche" and "reservable liabilities exemption amounts" c. 1982) & lower reserve ratios (requirements dropping by 40 percent c. 1990-91), and reserve simplification procedures (c. 2012), combined to remove reserve, and reserve ratio, restrictions.

Monetary policy should delimit all reserves to balances in their District Reserve bank (IBDDs, like the ECB), and have uniform reserve ratios, for all deposits, in all banks, irrespective of size (something Nobel Laureate Dr. Milton Friedman advocated, December 16, 1959).

The upcoming boom/bust will dwarf the GFC.
SalmoTrutta
  |     |   Comment #65
Savings accounts withdrawal limits simply represent the last vestige of the "monetization" of time deposits (from 1961 to 1981). The S-Curve” dynamic damage (sigmoid function) in money velocity, was completed by the first half of 1981.

Princeton Professor Dr. Lester V. Chandler, Ph.D., Economics Yale, theoretical explanation was:
1961 - “that monetary policy has as an objective a certain level of spending for gDp, and that a growth in time (savings) deposits involves a decrease in the demand for money balances, and that this shift will be reflected in an offsetting increase in the velocity of demand deposits, DDs.”
Chandler’s conjecture was correct from 1961 up until 1981.

Thus, the saturation of DD Vt (end game) according to Corwin D. Edwards, professor of economics. [Edwards attended Oxford University in England on a Rhodes scholarship and earned a doctorate in economics at Cornell University. He spent a year teaching at Cambridge University in England in 1932. He taught at New York University in 1954, the Chicago School from 1955-1963, the University of Virginia, and the University of Oregon from 1963-1971.]

Edwards: "It seems to be quite obvious that over time the “demand for money” cannot continue to shift to the left as people buildup their savings deposits; if it did, the time would come when there would be no demand for money at all”

That is, as stagnant (or frozen) time deposits became unhinged (the deregulation of Reg. Q ceilings), the velocity in the residual deposits were to be an offset in AD. The increased “demand for money” would thus be compensated in the turnover of the ungated transactions’ deposits.

--Michel de Nostradame
Jwunder
  |     |   Comment #66
Can anyone tell me with certainty weather or not the laws differ between a checking and savings acount as far as check holds are concerned it was y understanding the federal regulations prohibit a bank from withholding your funds from you longer then a few days.

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