How many withdrawals from a passbook savings account are you limited to, to be compliant monthly or quarterly? And does the term “withdrawals” include ACH transfers, loan payments, and in-person withdrawals?

To meet the definition of a “savings deposit” under Regulation D, a passbook savings account must be limited to six withdrawals “per calendar month or statement cycle (or similar period) of at least four weeks.”

The term “withdrawals” does include ACH transfers and loan payments for loans outside of your institution. However, in-person withdrawals and transfers to repay a loan with your institution are exempt. Regulation D exempts transfers made directly to the customer (or between accounts held by the same customer at your institution) if made “by mail, messenger, automated teller machine, or in person or when such withdrawals are made by telephone (via check mailed to the depositor).”

For resources related to our guidance, please see:

Federal Reserve Board, Consumer Compliance Handbook, Regulation D, page 3 (“Savings deposit accounts have the following characteristics: . . . allow no more than six transfers or withdrawals per calendar month or statement cycle of at least four weeks for the purpose of transferring funds to another of the depositor’s accounts at the same institution [unless initiated (1) in person, (2) by mail, (3) by ATM, or (4) by messenger] or making third-party payments by means of preauthorized, automatic, or telephonic transfers or transfers or withdrawals made by check, debit card, or other similar order made by the depositor and payable to third parties [and] allow unlimited withdrawals by mail, messenger, ATM, in person, or by telephone (via check mailed to the depositor) . . . .”)

Regulation D, 12 CFR 204.2(d)(2) (“The term ‘savings deposit’ also means: A deposit or account, such as an account commonly known as a passbook savings account . . . from which, under the terms of the deposit contract or by practice of the depository institution, the depositor is permitted or authorized to make no more than six transfers and withdrawals, or a combination of such transfers and withdrawals, per calendar month or statement cycle (or similar period) of at least four weeks . . . .”)

Regulation D, 12 CFR 204.2(d)(2) (The scope of “transfers and withdrawals” includes those made “by means of a preauthorized or automatic transfer, or telephonic (including data transmission) agreement, order or instruction, or by check, draft, debit card, or similar order made by the depositor and payable to third parties.”)

Regulation D, 12 CFR 204.2(d)(2) (“[A savings deposit] account is not a transaction account by virtue of an arrangement that permits transfers for the purpose of repaying loans and associated expenses at the same depository institution (as originator or servicer) or that permits transfers of funds from this account to another account of the same depositor at the same institution or permits withdrawals (payments directly to the depositor) from the account when such transfers or withdrawals are made by mail, messenger, automated teller machine, or in person or when such withdrawals are made by telephone (via check mailed to the depositor) regardless of the number of such transfers or withdrawals.”)