We would like to offer a money market product and would restrict the number of withdrawals from the account to one per month. Is this permissible? What disclosures would need to be provided?

Yes, we believe it is permissible to limit withdrawals from a money market account to one per month. Regulation D requires accounts classified as savings accounts to be limited to six transfers and withdrawals per month or statement cycle, but it does not prohibit banks from imposing more restrictive limitations.

Your bank’s Truth in Savings Act disclosures should clearly disclose the limitation on withdrawals, as well as any fees charged for withdrawals in excess of the one-per-month limitation.

For resources related to our guidance, please see:

  • 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 DD, 12 CFR 1030.4(b) (“Content of account disclosures. Account disclosures shall include the following, as applicable: . . .

(4) Fees. The amount of any fee that may be imposed in connection with the account (or an explanation of how the fee will be determined) and the conditions under which the fee may be imposed.

(5) Transaction limitations. Any limitations on the number or dollar amount of withdrawals or deposits.”)