Regulation D

What is Reg. D?

Reg. D is a federal regulation that limits the number and type of withdrawals from accounts that are intended for savings – including savings, money market and certificate of deposit accounts -- to six (6) per calendar month.

When the number of transactions exceeds six per month, it could result in a denied transaction. Further, we may be required to convert the account to a checking account, or even close the account under excessive or repeated circumstances. Effective October 1, 2019, withdrawals and overdrafts to cover debit transactions will be included in the six transactions allowed per month.

What is the purpose of Reg. D?
The purpose of Reg. D is to help ensure that people use their savings, money market and certificate of deposit accounts to save money. The regulation also helps ensure that banks and credit unions have the proper amount of reserves on hand.
How does Reg. D affect my account?
  • If you exceed the withdrawal limits set by Reg. D, your transactions will be denied. And, the account may have to be converted to a checking account or, in extreme cases, even closed.
What policy change is Firstmark making to comply with Reg. D?
Effective October 1, 2019, withdrawals and overdrafts cover debit transactions from these types of savings accounts will be included in the six (6) withdrawals allowed per calendar month.
What types of transactions are counted toward the six (6) transfers permitted each calendar month?
  • The types of transactions that count toward the six (6) transfers permitted each calendar month under Reg. D include:
  • ACH transfers from a savings or money market account to another financial institution or third party for payment by means of a preauthorized or automatic transfer, telephone agreement, order or instruction including SmartCall/Interactive Voice Response (IVR) or Online Banking, etc.
  • Withdrawal checks issued from a savings or money market account via IVR/Online Banking when made payable to a third party.
  • IVR/Online Banking transfers from a savings or money market account to any other Firstmark Credit Union account.
  • Automatic transfers from a savings or money market account to cover checks, ACH or EFT (overdraft protection).
  • Checking account Debit Card transactions, which overdraft from a savings or money market account when funds in the Checking account are insufficient.
  • Recurring scheduled transfers from a savings or money market account to any other Firstmark Credit Union account.
  • Telephone transfers conducted with a Firstmark representative.
What types of transactions are NOT counted toward the six (6) transfers permitted each calendar month?
  • The types of transactions that are NOT counted toward the six (6) transfers permitted each month under Reg. D include:
  • Withdrawal checks issued via IVR/Online Banking when made payable to the member and mailed to the member.
  • Any transfer for the purpose of repaying a Firstmark Credit Union loan.
  • Transfers among accounts of the same person when made by mail, ATM or in person.
  • Debit Card transactions that don’t trigger overdrafts from savings or money market accounts.
How can I make a withdrawal from a savings or money market account if I have exceeded the monthly limits set by Reg. D?
To make a transfer after the Reg. D limit has been exceeded, you can:
  • Transfer the money at an ATM
  • Complete the transaction in person with a teller
  • Use SmartCall to request a check to be mailed to you
  • Request a withdrawal transaction in writing and mail it to:  Firstmark Credit Union
    ATTN: Payment Systems P.O. Box 701650 San Antonio, TX 78270-1650
If I have two savings accounts; is the limit six (6) transactions for each account?
  • You are permitted a total of six (6) transfers per account, per calendar month.
Do ATM transfers from savings and money market accounts count toward Reg. D?
  • No, ATM transfers do not count toward the monthly Reg. D transaction limit.
Helpful Tips to Manage Your Account Transactions:
  • Have preauthorized payments (such as phone & utility bills) automatically deducted from a checking account, not a share savings account.
  • Make one large transfer to your Checking account to cover anticipated usage, instead of making many small transfers throughout the month.
  • Visit a branch or ATM location to make withdrawals or transfers.
  • Balance your Checking account to avoid overdraft transfers from your share savings account.
  • Apply for a Firstmark Line of Credit to use as overdraft protection.
  • Open a Firstmark Credit Union checking account. Checking accounts are not subject to Reg. D restrictions.