We are not aware of any law or regulation that would prohibit a money market account from being the only account associated with a debit card. Consequently, whether to offer debit cards for such accounts is a business decision for your bank. For Call Report purposes, whether to report a money market account that has had its transaction limits removed as a demand deposit (and as a “transaction account”) or as a savings deposit (and as a “nontransaction account”) depends on certain account features as discussed below.

In 2020, the Federal Reserve issued an interim final rule removing the six-per-month transaction limitation from the definition of “savings deposit” (which includes money market deposit accounts) under Regulation D. The FFIEC’s March 2022 Call Report Instructions provide that a reporting institution that has suspended enforcement of the six-transfer limit on an account meeting the definition of a savings deposit must report the account as a demand deposit (and as a “transaction account”) if the institution does not retain the reservation of right to require at least seven days’ written notice before an intended withdrawal. However, if an institution does retain this reservation of right, it may report the account as either a savings deposit (and as a nontransaction account) or a NOW account (and as a “transaction account”), if applicable.

If you report such accounts as transaction accounts on your Call Report, we believe you still may choose to refer to them as savings accounts (or money market accounts) internally and with your customers. The Federal Reserve’s Savings Deposits FAQs confirm that banks choosing to suspend enforcement of the six-transfer limit are not required to change the name of any accounts or products that have the words “savings” or “savings deposit” in the name of the account or product.

Note that the Federal Reserve’s Savings Deposits FAQs also state that an institution that suspends enforcement of the six-transfer limit may choose to report the account as either a transaction account or a savings deposit on its FR 2900 reports.

For resources related to our guidance, please see:

• Regulation D: Reserve Requirements of Depository Institutions Interim Final Rule, 85 Fed. Reg. 23445, 23446 (April 28, 2020) (“Because of the elimination of reserve requirements and because of financial disruptions related to the novel coronavirus, the Board is amending Regulation D, effective immediately, to delete the six transfer limit from the ‘savings deposit’ definition. This interim final rule includes deletion of the provisions in the ‘savings deposit’ definition that require depository institutions either to prevent transfers and withdrawals in excess of the limit or to monitor savings deposits ex post for violations of the limit.”)

• Regulation D, 12 CFR 204.2(d) (“(1) Savings deposit means a deposit or account with respect to which the depositor is not required by the deposit contract but may at any time be required by the depository institution to give written notice of an intended withdrawal not less than seven days before withdrawal is made, and that is not payable on a specified date or at the expiration of a specified time after the date of deposit. The term savings deposit includes a regular share account at a credit union and a regular account at a savings and loan association.

  (2) The term ’savings deposit‘ also means: A deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or as a money market deposit account (MMDA), that otherwise meets the requirements in paragraph (d)(1) of this section and from which, under the terms of the deposit contract or by practice of the depository institution, the depositor may be permitted or authorized to make transfers and withdrawals to another account (including a transaction account) of the depositor at the same institution or to a third party, regardless of the number of such transfers and withdrawals or the manner in which such transfers and withdrawals are made.”)

• March 2022 FFIEC Call Report Instructions (FFIEC 031 and 041), Schedule A-35, page 694 (“Where the reporting institution has suspended the enforcement of the six transfer limit rule on an account that meets the definition of a savings deposit, the reporting institution is required to report such deposits as a savings account or a transaction account based on an assessment of the characteristics of the account as indicated below:

(1) If the reporting institution does not retain the reservation of right to require at least seven days’ written notice before an intended withdrawal, report the account as a demand deposit (and as a ‘transaction account’).

(2) If the reporting institution does retain the reservation of right to require at least seven days’ written notice before an intended withdrawal, report the account as either a NOW account (and as a ‘transaction account’) or as a savings deposit (and as a nontransaction account).”)

• March 2022 FFIEC Call Report Instructions (FFIEC 031 and 041), Schedule A-35, page 694, footnote 1 (“The option to report as a NOW account (and a transaction account) is only applicable to institutions that offer NOW accounts and the account offered subsequent to the suspension of the enforcement of the six-transfer limit is equivalent to the reporting institution’s NOW account offering and is held by eligible depositors as authorized by federal law. Institutions that do not offer NOW accounts should continue to report such deposits as a savings deposit (and as a nontransaction account).”)

• Federal Reserve, Savings Deposits FAQs, #8 (May 13, 2020) (“If a depository institution chooses to suspend enforcement of the six-transfer limit on a ‘savings deposit,’ must the depository institution change the name of the account or product if the account or product name has the words ‘savings’ or ‘savings deposit’ in it? No. The interim final rule does not require depository institutions to change the name of any accounts or products that have the words ‘savings’ or ‘savings deposit’ in the name of the account or product.”)

• Federal Reserve, Savings Deposit FAQs, #5 (May 13, 2020) (“May depository institutions continue to report accounts as ‘savings deposits’ on their FR 2900 reports even after they suspend enforcement of the six-transfer limit on those accounts? Yes. Depository institutions may continue to report these accounts as ‘savings deposits’ on their FR 2900 reports after they suspend enforcement of the six-transfer limit on those accounts.”)

• Federal Reserve, Savings Deposit FAQs, #6 (May 13, 2020) (“If a depository institution suspends enforcement of the six-transfer limit on a ‘savings deposit,’ may the depository institution report the account as a ‘transaction account’ rather than as a ‘savings deposit’? Yes. If a depository institution suspends enforcement of the six-transfer limit on a ‘savings deposit,’ the depository institution may report that account as a ‘transaction account’ on its FR 2900 reports. A depository institution may instead, if it chooses, continue to report the account as a ‘savings deposit.’”)