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Regulation D was amended in 2009 to take away the 3 sub-limit that applied previously increasing it to 6 in all circumstances. But you are correct in that this

Regulation D was amended in 2009 to take away the 3 sub-limit that applied previously increasing it to 6 in all circumstances. But you are correct in that this is really a traditional rule that has been around for years. It is definitely becoming more of an issue as more and more people rely on online transfers and shy away from in-person banking (which is exempt from the rule as is ATM transfers). Are you sure about your last point? I have never heard of this, but I wouldn't be surprised if the bank lawyers found some type of loophole. But just to clarify the $25 I referenced is a returned ACH fee. The money is never actually transferred out of savings into checking when this happens.

oasisbob 15y ago
Ahhh, you're entirely right, I misremembered. Fees aren't required at all under Reg D (not Reg DD, damn alphabet soup). The FI does have a responsibility to monitor excess transactions and prevent non-occasional violations by either converting the account, or removing transactional abilities. So yeah, a token fee wouldn't be a viable strategy. Getting back to the topic at hand though, I don't think this would be much of a problem for fancy automatic transfers. Deposits to savings accounts aren't covered transactions, so something like "If I spend less than x budget this week, send the rest to savings" would work. If the FI designed a product that would see more frequent withdrawals, they could just designate it a transactional account and skip the whole issue entirely. Fits in the spirit and the letter of the law.