Original publication date: August 24, 2020
Question:
1) What is CRB's policy regarding Regulation D if we want to lift the restriction on an account prior to the next limit reset?
2) How is the block lifted after the reset?
3) Does the restriction include incoming transfers or only outgoing transfers?
4) Is there a bank policy for an account who had several Regulation D violations over a certain period of time?
Answer:
1) The CRB Regulation D policy is set at the partner level. It will only allow up to six pre-authorized debit transactions in a monthly cycle. This prevents the violation of Regulation D.
2) The block automatically resets the next month. We recommend that the customer be alerted to the number of pre-authorized debits they performed that month. When the sixth debit is reached, they should receive a notice which states the end of that cycle.
3) The block is for outbound transfers only.
4) CRB follows the rules set out in Regulation D and blocks outgoing transfers; we take no further steps. We recommend that you educate your customers about Regulation D and devise a strategy with them if this occurs repeatedly.