Yes, in order for an account to meet the definition of a NOW account under Regulation D, the bank must reserve the right to require at least seven days’ written notice prior to withdrawal or transfer of funds. Consequently, if you have classified an account as a NOW account on your Call Report, your institution must have reserved this right in your account disclosures.

For resources related to our guidance, please see:

• Regulation D, 12 CFR 204.2(e)(2) (“Transaction account includes: . . . (2) Deposits or accounts on which the depository institution has reserved the right to require at least seven days' written notice prior to withdrawal or transfer of any funds in the account and that are subject to check, draft, negotiable order of withdrawal, share draft, or other similar item, except accounts described in paragraph (d)(2) of this section (savings deposits), but including accounts authorized by 12 U.S.C. 1832(a) (NOW accounts).”)

• Instructions for Preparation of Consolidated Reports of Condition and Income (FFIEC 031 and 041), pg. A-18 (“NOW accounts are interest-bearing deposits (i) on which the depository institution has reserved the right to require at least seven days' written notice prior to withdrawal or transfer of any funds in the account and (ii) that can be withdrawn or transferred to third parties by issuance of a negotiable or transferable instrument.”)