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FDIC Federal Register Citations


Sent: Monday, September 17, 2001 3:02 PM
To: Comments
Subject: Comment on Study of Banking Regulations re: Online Banking

It is clear�that online banking�is a major component of�where banking�is headed in the future.� A regulation that impedes the promotion of, and use of, online banking is Regulation D.� This regulation puts limitations on how many times a "preauthorized transfer" can be made during the course of a month.��A "preauthorized transfer" includes transfers�from savings and money market accounts�that can be conveniently made via online banking.��
The preauthorized transfer limitation of six has been in effect for several years.� Since that time, banking has expanded it's services to include telephone banking, ATM's, and now, online banking.� All of these vehicles have made banking more convenient.� However, if money is transferred from savings or money market accounts using these vehicles, it is counted in the limitation of six.�
On one hand�we are introducing and promoting�these products, and on the other hand,�we are notifying�customers�that they have exceeded their transfer limitation�and have violated the law.���
Not long ago, legislation was pending that would increase the limit to twenty-four transfers per month; however, this would only apply to commercial accounts.� Please consider increasing the preauthorized transfer limitation imposed by Regulation D for all accounts.�
Julie Smith, Compliance Officer
Farmers & Merchants State Bank
Springfield, MN� 56087
507.723.4800
Last Updated 09/18/2001 regs@fdic.gov

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