Reg D Monitoring: Reg D Counter Warnings for Phone Operator and Online Banking Transfers

Helpful messaging will alert your member service staff when a Phone Operator transfer will exceed the number of transfers allowed by the Reg D requirements for the account. These warning messages will appear with Phone Operator transfers since with these transactions the member would not be there in person, and therefore, the transfer would apply to the Reg.  Additionally the member can be presented warning messages in online banking when their transfer will exceed the allowed amount

Learn more about Reg D configuration

Monitoring Dividend Applications Against Red Flag Monitoring

To have transactions of certain accounts be counted against Reg D monitoring, the following steps must be taken.

SEE ALSO: REG D Configuration.

  1. Check the Reg D transaction account flag in the Dividend Application configuration.

  2. Alter your Reg D configuration to count the Transaction Origin Code 15 (Phone Operator transfer) and if selected, your Transaction Origin Code 96 (Audio banking, which applies to online banking transfers).  

    • NOTE:  This starts the warnings in Phone Operator right away. You may need to define your policy for handling this Reg D warning message and provide additional training to your staff on your new policies.

    • For Online Banking: To activate this feature for Online Banking, check Generate Reg D warning message in online banking on the Reg D Transaction Policy screen and use Enter to save the change.  Then click Message Text (F12) and enter the warning message you would like your members to see in online banking. Then use Update (F5).  One item to consider would be to alert members of any fee they may be charged, if applicable.

    • IMPORTANT NOTE:  Remember that CU*BASE only warns employees/members when the limit is about to be hit; it will never stop a member from being able to access his or her money.

  1. Monitor the daily report for violators:  PRGDTX - Regulation D Violation Register and PREGD - Regulation D Statistics Report.  Refer to the Reg D configuration topic for examples of these reports.

  2. If you want to charge fees for Reg D transfers over the limit, we recommend using the Transaction Service Charge feature to set up either a daily or a monthly service charge based on transactions posted to your Reg D products.  Configuring Transaction Service Charges

When a credit union employee makes a transfer through Phone Operator or a member makes a transfer in online banking from an account affected by Reg D, per the "Reg D transaction account" in the Dividend Application being checked), the following process is followed:

  1. Each time an employee enters the Transfer screen  (or if online banking warning messages are activated when the member makes a transfer), CU*BASE checks to see if the transaction that is about to be made is flagged as Reg D in the Reg D configuration.  

  2. If the transaction is from an account that with a Dividend Application configured for Reg D, then CU*BASE verifies that the transfer is not being made to one of your loan accounts (not included in Reg D transfer count).   See above for process on how this is configured.

  1. If the transfer is not to a loan account, then CU*BASE takes the existing Reg D counter* for that account (which includes all of the Reg D transfers already made), adds 1 (for the transfer that’s about to happen.

Phone Operator Experience of Reg D Warning

For Phone Operator transfers (if configured - see above)

CU*BASE displays that total on the screen to alert the employee.  (The same count increased when a member makes a transfer in online banking, but members do not see a counter.)

images\regdcounter_shg.gif

  • If posting this transaction would cause the account to exceed the allowed number, CU*BASE also displays a warning message: images\regdtransferwarning_shg.gif

Online Banking Experience of Reg D Warning

For online banking transfers (if activated - see above)

  • If members make a transfer that would cause the account to exceed the allowed number, they will see the warning message you have configured on this screen.  They see this warning at the top of the page in desktop and mobile web banking,  It is just a warning and will not stop the member from making the transfer.