Summary:

Effective April 24, 2020, the Federal Reserve issued an interim final rule amending Regulation D to remove the required limitation of transfers on certain types of transfers and withdrawals made each month from savings deposits. There are no mandatory changes to deposit reporting associated with the amendments and at this time there is no indication whether this change will be permanent or temporary in the interim final rule. 

Logicpath Response: 

Logicpath continues to absorb recent Regulation D communication dated 4/24/20 and found in the Federal Register as it pertains to deletion of the numeric requirement of transfer monitoring. Logicpath has contacted the Federal Reserve for clarity on recent changes in addition to monitoring comments on the interim final rule through 6/29/2020. 

https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200424a1.pdf 

Logicpath has fielded client questions regarding the continuation of use of Deposit Reclassification as a result of this final interim rule as well as the reduction of the reserve requirement ratio to 0%. 

Market uncertainty, continued fluidity in macro-economic conditions, medical protocols with tangential impact to economic policy and unprecedented Federal Reserve intervention to market activities contribute to Logicpath’s advisement to clients. 

Logicpath's position at this time is for clients to continue processing accounts through the application and post totals to the FR 2900 and Call Report schedules as usual and permitted via the interim final rule. In light of current pandemic response and anticipated further Federal Reserve actions we believe that additional regulatory change is quite possible and advise clients to wait for finality of these actions before moving away from Deposit Reclassification use as there is a possibility that reserve ratios may adjust in the future. 

We deeply value our relationships and understand that there are going to be many questions asked as we collectively navigate these unfolding economic changes. Please continue to contact us at support@logicpath.com for questions regarding interpretations on these changes or application use