CBA Letter in Support of Regulation D Study

June 3, 2015


The Honorable Gene Dodaro Comptroller General of the United States

U.S. Government Accountability Office 441 G Street, NW

Washington, D.C. 20548 Dear Mr. Dodaro:

As the voice of the retail banking industry, the Consumer Bankers Association (CBA) writes in support of a Government Accountability Office (GAO) study and report on the impact of the requirement that depository institutions maintain reserves in accordance with subsections (b) and

(c) of section 19 of the Federal Reserve Act and Regulation D as requested by House Financial Services Committee Chairman Jeb Hensarling (R-TX) and Congressman Robert Pittenger (R- NC).


The Federal Reserve’s Regulation D limits consumers to six transfers per month from their savings account to any other accounts. Yet, it does not limit transfers via ATM, teller or mail since those were the most common transaction types when the regulation was originally implemented.  Today’s consumers, especially those utilizing online and mobile banking, demand greater flexibility to transfer funds between accounts.  In fact, CBA member banks’ customers are often confused and inconvenienced by the current transfer limit.  While the CBA recognizes the important role reserve requirements can play in implementing monetary policy, the transfer limit should be reexamined to ensure there is an appropriate balance between the needs of monetary policymakers and the modern consumer.


The study and report requested by Chairman Hensarling and Congressman Pittenger mirror the goals of H.R. 3240, the Regulation D Study Act, which was approved by the House of Representatives on December 2, 2014, by a vote of 422-0.  Importantly, this study would examine the transfer limit’s impact on the maintenance of reserves at depository institutions and the ability of consumers to manage their accounts.


The CBA encourages the GAO to complete this important study and stands ready to serve as a resource to the agency as it evaluates the transfer limit’s impact on depository institutions and their customers.



Richard Hunt

President and CEO

Consumer Bankers Association