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NAFCU Monday discussed with the CFPB the Federal Reserve's recent interim final rule that eliminates the six-per-month transaction limit between savings and checking accounts under Regulation D and credit unions' concerns regarding how this change could impact Regulation CC compliance.

The Fed's interim final rule allows credit unions to eliminate transfer and withdrawal limits on savings account and other products that meet the definition of a savings deposit. As a result, the rule reduces the compliance costs associated with monitoring and enforcing the transfer limit.

A recent NAFCU Compliance Blog post flagged that Regulation CC uses Regulation D's definitions for determining which accounts are subject to rules related to the availability schedule for deposited checks. The specific definitional amendments to Regulation D have created some confusion regarding what accounts are subject to funds availability rules.

During Monday's discussion, NAFCU shared these concerns and asked the CFPB how it might resolve the ambiguity in a way that is least disruptive to credit unions. The association also sent a letter to the Fed Monday asking for clarification that the rule's changes are permanent.

NAFCU has long advocated for this transaction limit to be lifted and will continue working with the Fed to ensure it is a permanent elimination and clarify Regulation CC implications with the Fed and CFPB.