Fed Issues Regulation D ANPR
On March 6, 2019, the Federal Reserve Board (Fed) issued an Advance Notice of Proposed Rulemaking (ANPR) on whether to amend Regulation D. Regulation D imposes reserve requirements on certain deposits and other liabilities of financial institutions in order to implement monetary policy. It dictates how financial institutions must classify different types of deposit accounts for reserve requirements purposes and imposes transaction limitations on certain accounts. Unfortunately for financial institutions, this APNR does not address the transaction limitations. Instead, the APNR invites public comment on whether the Fed should lower the rate of interest paid on excess balances maintained at Reserve Banks by eligible institutions that hold a very large proportion of their assets in the form of balances at Reserve Banks.
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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