Your bank may continue to report such accounts as nontransaction savings deposits for Call Report purposes; however, your bank has the option of reporting such accounts as transaction accounts if certain criteria are met.

The December 2020 COVID-19 Related Supplemental Instructions for Call Reports state that when a reporting institution has suspended the enforcement of the six transfer limit on an account that meets the definition of a “savings deposit” it may continue to report the account as a savings account (a type of savings deposit) or it may choose to report the account as a transaction account (following the instructions provided for distinguishing between the transaction account types of demand deposits, ATS accounts, NOW accounts, and telephone and preauthorized transfer accounts).

However, the COVID-19 Related Supplemental Instructions note that you should continue reporting an account as a savings deposit if you reserve the right to require at least seven days’ written notice before a customer can make a withdrawal and the customer is ineligible for a NOW account. Consequently, it appears that your savings accounts must be reported as savings deposits on your Call Reports if held by a customer who is ineligible for a NOW account and if you have reserved the right (for example, in your account agreement) to require seven days’ written notice of withdrawals; otherwise, you have the option to report these accounts as savings deposits or transaction accounts.

If you choose to report such accounts as transaction accounts on your Call Report, we believe you may continue to refer to the accounts as savings 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.

For resources related to our guidance, please see:

• December 2020 COVID-19 Related Supplemental Instructions (Call Report), printed page 30 (“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 may continue to report such deposits as a savings account, or may choose to report them as transaction accounts 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.

2) If the reporting institution does retain the reservation of right to require at least seven days’ written notice before an intended withdrawal and the depositor is eligible to hold a NOW account, report the account as either an ATS account, NOW account, or a telephone and preauthorized transfer account.

3) If the reporting institution does retain the reservation of right to require at least seven days’ written notice before an intended withdrawal and the depositor is ineligible to hold a NOW account, the account should continue to be reported as a savings deposit.”)

• December 2020 COVID-19 Related Supplemental Instructions (Call Report), Appendix C, printed page 28 (“Savings deposits are deposits 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 also means a deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or a money market deposit account (MMDA), that otherwise meets the requirements of the preceding paragraph.” [All of the requirements related to the six transfer limitation have been stricken out.])

• December 2020 COVID-19 Related Supplemental Instructions (Call Report), printed page 17 (“On April 28, 2020, the Board published an interim final rule amending its Regulation D (12 CFR 204) to delete the numeric limits on certain kinds of transfers and withdrawals that may be made each month from ‘savings deposits.’ In response to the changes to Regulation D, the definitions of certain deposits reported on Call Report Schedule RC-E, Deposit Liabilities, have been revised. See Appendix C for the redlined revisions to these deposit definitions in the instructions for Schedule RC-E, Deposit Liabilities, and the Glossary entry for ‘Deposits.’”)

• December 2020 COVID-19 Related Supplemental Instructions (Call Report), Appendix C, printed page 26 (“NOW accounts, as authorized by federal law, are limited to accounts held by: (i) Individuals or sole proprietorships; (ii) Organizations that are operated primarily for religious, philanthropic, charitable, educational, or other similar purposes and that are not operated for profit. . . . or (iii) Governmental units . . .  Also included are the balances of all NOW accounts of certain other nonprofit organizations that may not fall within the above description but that had established NOW accounts with the reporting institution prior to September 1, 1981.”)

• 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.”)