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Is an individual retirement account (IRA) considered a “savings account” under Regulation D? – IBA Compliance Connection

IBA Compliance Connection

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Is an individual retirement account (IRA) considered a “savings account” under Regulation D?

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If your institution wishes to characterize its IRAs as savings accounts for purposes of your reserve requirements under Regulation D, the IRAs must meet Regulation D’s definition of a “savings deposit.” To meet this definition, your account agreements must reserve the bank’s right to require at least seven days’ prior written notice of a withdrawal, create no maturity date, and impose a limit of six withdrawals per month via pre-authorized or automatic transfer, check, draft, debit card, telephone, or similar order made by the depositor and payable to third parties. If your bank establishes IRAs such that they comport with these requirements, the IRAs would be considered savings deposits.

For resources related to our guidance, please see:

  • 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.”)
  • 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, a statement savings account, or as a money market deposit account (MMDA), that otherwise meets the requirements of § 204.2(d)(1) and 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, to another account (including a transaction account) of the depositor at the same institution or to a third party 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. . . .”)
  • Federal Reserve Board, Consumer Compliance Handbook, Regulation D, page 3 (“Savings deposit accounts have the following characteristics: . . . .”)